In the case of Morris Canal and Banking Company v. Baird (1915), the United States Supreme Court ruled on a dispute involving property rights. The Morris Canal and Banking Company had sold land to George W. Coudert, who later transferred it to William Baird Jr., with both transactions including mineral rights but excluding oil and gas rights. When oil was discovered on the land, a legal battle ensued over who held these valuable extraction rights: Baird or the original owner, Morris Canal and Banking Co. The court decided in favor of Baird by applying New Jersey law which stated that unless explicitly reserved in a deed transfer, all property interests pass to the grantee - meaning that when Coudert bought from Morris he acquired everything not specifically excluded (including oil). This decision upheld previous rulings stating that "in this country...the common-law rule is...that ownership of soil carries with it ownership also of space above & minerals below." Thus, since neither sale contract mentioned reserving oil/gas for seller's benefit they were deemed part of what got sold each time.

In the dissenting opinion for Morris Canal and Banking Company v. Baird, Justice Holmes disagreed with the majority's decision to allow a mortgagee to recover rents from mortgaged premises that were in possession of a receiver during foreclosure proceedings. He argued that when a mortgage is given on real estate, it should be understood as security for debt rather than an absolute conveyance of property rights. Therefore, he believed that any income generated by the property (such as rent) should go towards paying off the debt owed by the mortgagor before being claimed by other parties such as receivers or trustees in bankruptcy cases. This interpretation would prioritize repayment of debts over distribution of assets among creditors which he felt was more consistent with principles of equity and fairness.