In the case of Las Animas Land Grant Company v. United States in 1900, the Supreme Court was asked to determine whether a land grant made by Mexico before it ceded territory to the U.S. under the Treaty of Guadalupe Hidalgo included mineral rights. The Las Animas Land Grant Company claimed ownership over gold and silver mines within its granted lands based on Mexican law at that time which they argued gave them such rights implicitly with their surface rights. However, after examining historical documents and legal precedents from Spanish and Mexican law, as well as considering American mining laws, the court ruled against this interpretation. It held that while grantees were given broad use of surface resources like timber or grass for grazing livestock, sub-surface mineral wealth remained property of the sovereign unless explicitly granted otherwise - a principle carried forward when sovereignty transferred to America post-treaty.

In the dissenting opinion for the case of Las Animas Land Grant Company v. United States, it was argued that the majority's decision to uphold a lower court ruling denying Las Animas' claim to certain lands in Colorado was incorrect. The dissenting justices believed that under Spanish and Mexican law, which governed at the time when Mexico ceded this territory to U.S., land grants could include both specific parcels of land as well as additional adjacent or nearby lands necessary for their use and enjoyment (known as "pertinentes"). They contended that these pertinentes were implicitly included in any grant unless specifically excluded. Therefore, they felt that Las Animas had a valid claim on not only its granted parcel but also surrounding areas needed for grazing cattle - an essential part of its ranching operations. This interpretation differed from majority’s view who held such claims should be explicitly mentioned in grant documents.