The U.S. Supreme Court case Pittsburgh and Lake Angeline Iron Company v. Cleveland Iron Mining Co in 1899 revolved around a dispute over iron ore mining rights on land located in Michigan's Upper Peninsula. The Pittsburgh and Lake Angeline Iron Company claimed that the Cleveland Iron Mining Co had trespassed onto their property to mine for iron, thereby infringing upon their exclusive mining rights granted by an earlier lease agreement with the original landowner. However, the Cleveland company contended that they were operating within their own adjacent parcel of land which was demarcated by metes and bounds (a system of describing boundaries). The court ruled in favor of the defendant, stating that there was insufficient evidence to prove trespassing or violation of property rights as alleged by the plaintiff because it could not be definitively established whether or not any encroachment occurred due to unclear boundary descriptions.

In the dissenting opinion for Pittsburgh and Lake Angeline Iron Company v. Cleveland Iron Mining Co, Justice Harlan argued that the majority's decision was incorrect because it failed to consider important aspects of contract law. He contended that a contract should be interpreted based on its language and intent at the time it was made, not retroactively applied with new conditions or interpretations. In this case, he believed that when the original lease agreement between both parties was signed in 1852, there were no stipulations about mining operations ceasing if iron ore prices fell below a certain level. Therefore, he disagreed with the majority's ruling which allowed Cleveland Iron Mining Co to stop paying royalties after they ceased mining due to low iron prices. For him, such an interpretation contradicted basic principles of contractual obligations and set a dangerous precedent for future cases involving similar disputes.