In the 1891 case of Leadville Coal Company v. McCreery, the United States Supreme Court ruled in favor of McCreery. The dispute arose over a coal mining lease agreement between both parties where Leadville agreed to mine at least 100 tons of coal per day from McCreery's property and pay him $0.25 per ton as royalty. However, due to technical difficulties and financial constraints, Leadville was unable to meet this quota but continued its operations on the leased land without paying any royalties for extracted coal below the daily minimum requirement. The court held that despite not meeting their contractual obligations fully, since they were still extracting resources from McCreery's land, they were obligated to pay him royalties for all mined coal regardless of quantity extracted each day. This ruling established an important precedent regarding resource extraction leases - even if a lessee fails to meet their minimum production requirements under such agreements; they are still liable for payments based on actual production levels.

In the dissenting opinion for Leadville Coal Company v. McCreery, it was argued that the majority's decision to uphold a Colorado statute requiring coal mining companies to pay their employees at least once a month in lawful money rather than company scrip was an overreach of state power and violated the Fourteenth Amendment. The dissent believed that this law interfered with private contracts between employers and employees, which should be protected under freedom of contract principles. They contended that if both parties agreed to payment terms involving company scrip, then there should not be any legal issue with such an arrangement. Furthermore, they expressed concern about potential economic consequences from limiting how businesses could compensate workers and warned against excessive government interference in labor relations.