In the case of Lane, Secretary of the Interior v. Hoglund (1916), the Supreme Court dealt with a dispute over land rights in Alaska. The plaintiff, Hoglund, had staked a claim on a piece of land under an 1898 law that allowed individuals to claim up to 160 acres for agricultural purposes. However, this was challenged by Lane, who argued that since there were valuable minerals on the property and it was not being used solely for agriculture as required by law; therefore it should be considered public lands open to mining claims instead. The court ruled in favor of Hoglund stating that even though he did not strictly use his land for farming or ranching activities only but also mined gold from it occasionally; still he complied with all other requirements set forth in said act such as living upon and improving said tract continuously which made him eligible under homestead laws hence his title could not be contested based on occasional mining activity alone.

In the dissenting opinion for Lane v. Hoglund, it was argued that the majority's decision to deny a homesteader his claim on land because he had not built a dwelling within six months of filing contradicted previous court rulings and interpretations of the Homestead Act. The dissenting justices believed that this strict interpretation ignored other factors such as good faith efforts by settlers to comply with requirements, including making improvements on their claims or establishing residence elsewhere due to harsh winter conditions. They also pointed out inconsistencies in how different cases were treated under similar circumstances, arguing for more leniency and flexibility in interpreting laws related to homesteading rights.