In the case of Pronovost v. United States in 1913, the U.S Supreme Court ruled on a dispute involving land ownership and mining rights. The plaintiff, Pronovost, claimed that he had purchased a piece of property from an individual who had obtained it through a patent issued by the United States government. However, after purchasing this property, Pronovost discovered that there was another claim to his land: A mining company asserted they held prior mineral rights to the same parcel of land due to their pre-existing operation on it before its sale. The court ultimately decided in favor of the defendant -the U.S Government- stating that when issuing patents for public lands containing valuable minerals such as gold or silver (known as lode claims), these specific mineral rights are not included unless explicitly stated so within the patent's language. Therefore, even though Pronovost bought and owned surface rights to his property via his purchase agreement with previous owner; he did not own any subsurface mineral deposits present because those were never part of what was sold originally by federal authorities.

In the dissenting opinion for Pronovost v. United States, it was argued that the defendant's conviction should be overturned due to a lack of evidence proving his intent to defraud. The dissenting justices believed that while Pronovost may have been guilty of negligence or even recklessness in handling bank funds, there was insufficient proof he intended to deceive or cheat anyone. They pointed out that fraud requires an element of deceit and dishonesty which they did not believe had been adequately demonstrated by the prosecution in this case. Furthermore, they disagreed with the majority's interpretation of "intent," arguing instead for a narrower definition requiring clear evidence of fraudulent intent rather than mere carelessness or poor judgment.