In the 1911 case Plummer v. United States, the Supreme Court ruled on a matter involving land rights and mining claims in Alaska. The plaintiff, Plummer, had staked a claim to mine gold on public lands in Alaska but was later told by federal officials that his claim was invalid because it overlapped with an earlier one made by another party. He sued for damages arguing that he had invested significant resources into developing the mine based on assurances from local land officers that his claim was valid. However, the Supreme Court upheld lower court decisions against him stating that local land officers did not have final authority over such matters and their approval of his claim did not protect him from subsequent challenges or changes in determination about its validity.

In the dissenting opinion for Plummer v. United States, it was argued that the majority's decision to uphold Plummer's conviction on charges of embezzlement was incorrect due to a lack of evidence proving intent. The dissenting justices believed that there were insufficient facts presented at trial to prove beyond reasonable doubt that Plummer had intended to defraud or embezzle from his employer. They contended that while he may have made errors in bookkeeping and financial management, these mistakes did not necessarily equate with criminal intent. Furthermore, they disagreed with the majority's interpretation of relevant laws and statutes related to embezzlement, arguing instead for a more stringent standard requiring clear proof of fraudulent intent before convicting someone on such serious charges.