In the case of Mecom v. Fitzsimmons Drilling Co., Inc., the Supreme Court ruled in 1931 on a dispute over oil drilling rights in Louisiana. The plaintiff, Mecom, was an administrator for a deceased individual's estate that owned land where oil was discovered. Fitzsimmons Drilling Co., who leased adjacent property, drilled diagonally and extracted oil from beneath the decedent’s property without consent or compensation to the owner. The court held that such extraction constituted trespassing under Louisiana law and ordered Fitzsimmons to pay damages equivalent to the value of wrongfully extracted oil plus interest. This ruling established important precedent regarding subsurface mineral rights and clarified that unauthorized diagonal drilling constitutes trespassing.

The dissenting opinion in the Mecom v. Fitzsimmons Drilling Co., Inc. case argued that the majority's decision to uphold a Louisiana statute was incorrect because it violated the Due Process Clause of the Fourteenth Amendment. The dissent contended that this law, which allowed an administrator of an estate to sue for damages resulting from a wrongful death even if no such action had been initiated before death, unfairly imposed liability on defendants without giving them proper notice or opportunity to defend themselves against these claims during their lifetime. This, according to the dissenting justices, constituted a deprivation of property without due process and thus conflicted with constitutional principles.