In the case of Rio Grande Irrigation and Colonization Company v. Gildersleeve (1898), the U.S Supreme Court was tasked with resolving a dispute over water rights in Colorado. The plaintiff, Rio Grande Irrigation and Colonization Company, claimed that they had prior appropriation to use water from the Rio Grande River for irrigation purposes. They argued that their right to this usage superseded any subsequent claims by other parties, including defendant Gildersleeve who also sought access to these waters for his own land irrigation needs. The court ruled in favor of the plaintiff based on Colorado's doctrine of prior appropriation which prioritizes "first in time, first in right". This means that those who first put water resources to beneficial use have superior rights over later users regardless of land ownership proximity to source bodies of water. Therefore, since Rio Grande Irrigation and Colonization Company demonstrated earlier beneficial use than Gildersleeve did, it retained its priority claim on using said waters.

In the dissenting opinion for Rio Grande Irrigation and Colonization Company v. Gildersleeve, Justice Harlan disagreed with the majority's interpretation of a contract between the parties involved. He argued that there was no ambiguity in the contract terms and it should be interpreted as written without resorting to extrinsic evidence or speculation about what might have been intended by either party. The justice believed that under this clear contractual agreement, Rio Grande Irrigation and Colonization Company had an obligation to deliver water rights to Gildersleeve which they failed to do so adequately. Thus, he would have affirmed the lower court's decision in favor of Gildersleeve instead of reversing it as done by his colleagues on bench.