In the Mackay v. Uinta Development Company case of 1912, the United States Supreme Court dealt with a dispute over land ownership and mineral rights in Utah. The plaintiff, John W. Mackay, claimed that he had purchased mining property from an individual who had obtained it through a patent issued by the U.S government under its Mining Laws. However, Uinta Development Company contested this claim on grounds that they owned part of the same property due to their purchase from another party who held title via railroad grant legislation passed by Congress for Union Pacific Railroad's benefit. The court ruled in favor of Mackay stating that when two federal laws conflict - one granting land to railroads and another allowing individuals to stake mining claims - priority should be given to those staking mining claims if they were first in time. This decision was based on established legal principles which prioritize "first in time" rights as well as specific language within both pieces of legislation indicating Congressional intent for miners' rights protection against subsequent conflicting grants.

In the dissenting opinion for Mackay v. Uinta Development Company, it was argued that the majority's decision to uphold a lower court ruling allowing Uinta Development Company to retain land originally granted by Congress but later rescinded was incorrect. The dissenting justices believed that once Congress had rescinded its grant of land, all rights and privileges associated with that grant were also revoked. Therefore, they contended, Uinta should not have been able to keep the land in question because their right to do so was dependent on a congressional grant which no longer existed. They further argued that this interpretation aligned more closely with legislative intent and precedent than did the majority's decision.