The Montello Salt Company v. State of Utah case in 1910 revolved around the issue of land ownership and mineral rights. The Montello Salt Company claimed that they had acquired certain lands under an Act of Congress from 1866, which granted them not only the surface rights but also all minerals beneath it. However, the state of Utah argued that a subsequent Act in 1877 limited such grants to include only agricultural lands and did not extend to valuable mineral deposits like salt. The Supreme Court ruled in favor of Utah, stating that while the original act may have been ambiguous about whether it included minerals or not, any ambiguity was resolved by later legislation and administrative interpretation against including such valuable substances within its purview unless expressly mentioned. Therefore, despite having title to these lands for many years under apparent authority from federal officers who administered public land laws at those times, Montello's claim over salt reserves was rejected.

The dissenting opinion in the case of Montello Salt Company v. State of Utah argued that the state's right to tax should not be limited by a federal statute, unless it is explicitly stated within said statute. The justice disagreed with the majority view that Congress had intended to exempt lands containing valuable mineral deposits from taxation when they passed an 1875 law granting rights-of-way through public lands for construction of highways and railroads. He pointed out that this interpretation was inconsistent with other rulings where similar grants were held not to convey ownership or control over resources beneath the surface, but merely surface rights necessary for transportation purposes. Furthermore, he contended there was no evidence suggesting Congress intended such a broad exemption from taxation as interpreted by the majority; rather, it seemed more likely they simply overlooked potential implications on state taxing powers when drafting legislation focused primarily on encouraging development of infrastructure.