In the case of Huffman et al. v. Western Nuclear, Inc., et al., 1987, the U.S. Supreme Court was tasked with determining whether gravel found beneath a piece of land constituted a "valuable mineral" under the Stock-Raising Homestead Act (SRHA) of 1916 and thus belonged to the federal government or if it belonged to Western Nuclear, Inc., who owned surface rights to that land through patent from SRHA. The court ruled in favor of Huffman and other federal appellants by holding that gravel did indeed qualify as a valuable mineral reserved by United States under SRHA because its extraction is similar to traditional mining operations and it has commercial value for use in construction industry; hence, ownership remained with the federal government despite surface rights being granted via homesteading laws.

In the dissenting opinion for Huffman et al. v. Western Nuclear, Inc., et al., Justice Stevens argued that the majority's interpretation of "minerals" in the Stock-Raising Homestead Act of 1916 was too broad and inconsistent with historical context. He contended that gravel should not be classified as a mineral under this act because it is common and does not have significant value like other minerals such as gold or silver do. Furthermore, he pointed out that at the time when this law was enacted, gravel would likely not have been considered a valuable resource to reserve for federal ownership due to its abundance and low worth compared to more precious minerals. Therefore, according to Justice Stevens' interpretation of legislative intent behind this statute, private landowners should retain rights over gravel found on their property rather than these resources being controlled by federal government.