The U.S. Supreme Court case Lane v. Watts in 1913 revolved around a dispute over land rights and the interpretation of an 1866 Act of Congress that granted lands to railroads for construction purposes. The Secretary of the Interior, Franklin K. Lane, argued that certain lands were not included within this grant due to their classification as mineral lands at the time when they were surveyed by government officials, thus making them ineligible for railroad grants under the terms of the act. On behalf of his client Mr. Watts, who had purchased some parcels from a railroad company believing them to be part of its original grant, attorney William D Mitchell contended that these lands should have been included in the grant because they did not contain valuable minerals and therefore could not be classified as mineral lands. In its decision, however court sided with Lane's argument stating that whether or not these particular plots contained valuable minerals was irrelevant; what mattered was how they were officially classified at time surveying took place which determined their eligibility under terms set out by Congress' act.

In the dissenting opinion for Lane v. Watts, it was argued that the Secretary of Interior did not have the authority to cancel a land patent once it had been issued and recorded. The dissenting justices believed that this power belonged solely to the courts, not an administrative official. They contended that allowing such cancellations would undermine property rights and create uncertainty in land ownership as patents could be revoked at any time by a government official without due process or judicial review. This view held that only through legal proceedings where evidence is presented and evaluated can a decision on cancellation be made fairly and justly.