In the case of Mitchell v. Smale in 1890, the U.S Supreme Court was tasked with determining whether a mining claim could be invalidated due to an incorrect description on its patent application. The court ruled that if there is no intent to deceive and if all other legal requirements are met, such as proper use and improvement of the land, then minor inaccuracies in location descriptions do not invalidate a mining claim. This decision upheld previous rulings which stated that patents issued by the government are presumed valid until proven otherwise. Therefore, any party challenging this validity has to provide clear evidence of fraud or mistake beyond reasonable doubt.

The dissenting opinion in the Mitchell v. Smale case argued that the majority's decision to uphold a lower court ruling, which allowed for the seizure of property as payment for debt without due process, was unconstitutional. The dissenting justices believed this violated the Fourteenth Amendment’s protection against deprivation of property without due process of law. They contended that seizing someone's property to satisfy a debt should only be done after giving them an opportunity to contest it in court and not arbitrarily by creditors or their agents. Furthermore, they expressed concern about potential abuses if such seizures were permitted without judicial oversight or safeguards against wrongful seizures. They also disagreed with the majority's interpretation of previous rulings on similar issues, arguing that those cases did not establish a precedent allowing for such actions but rather emphasized respect for individual rights and procedural fairness under law.