In the case of Shumate v. Heman in 1900, the United States Supreme Court ruled on a dispute involving land ownership and mineral rights. The plaintiff, Shumate, claimed that he had purchased land from Heman with an agreement that included all mineral rights to the property. However, when oil was discovered on the land years later, Heman argued that he still retained those rights as they were not explicitly mentioned in their original contract. The court sided with Shumate stating that unless specifically reserved by the seller at time of sale or clearly stated otherwise within contractual agreements between buyer and seller; upon selling real estate property it is presumed under law to include everything above and below ground (surface & subsurface) - including any potential minerals or other valuable resources found therein.

The dissenting opinion in the case of Shumate v. Heman argued that the majority's decision was incorrect because it failed to properly interpret and apply relevant bankruptcy law. The dissent believed that a debtor should not be able to use bankruptcy proceedings as a means of avoiding payment on an existing debt, particularly when there is evidence suggesting fraudulent intent. They contended that allowing such behavior undermines faith in the legal system and unfairly penalizes creditors who are owed money. Furthermore, they disagreed with the majority's interpretation of what constitutes "property" under bankruptcy law, arguing for a broader definition which includes potential future income or assets rather than just current holdings at time of filing for bankruptcy.