In Shurtleff v. United States (1902), the U.S Supreme Court dealt with a case concerning land patents and mining rights in California. The plaintiff, Shurtleff, claimed that he had been unlawfully dispossessed of his property by the defendant, who had obtained a patent for it from the government. He argued that because he was already in possession of and working on this land when the defendant applied for their patent, his rights should be recognized over those of the defendant's. The court ruled against Shurtleff stating that under federal law at that time - specifically Section 2326 of Revised Statutes - an individual could not claim exclusive right to mine public lands until they have complied with all legal requirements including obtaining necessary permits or licenses from relevant authorities. In this case, while Shurtleff may have been first to work on these lands; however since he did not comply with statutory requirements before starting operations thereon nor did he obtain any formal recognition or approval from competent authorities as required by law; hence his claims were dismissed.

In the dissenting opinion for Shurtleff v. United States, Justice Harlan disagreed with the majority's interpretation of the law regarding land patents. He argued that a patent issued by the government is conclusive evidence of its validity and cannot be challenged in court unless there is clear proof of fraud or mistake. According to him, it was not enough for someone to simply claim they had a better right to the land; they needed solid evidence proving their case beyond reasonable doubt. Furthermore, he believed that once a patent has been issued, it should only be set aside if there are compelling reasons showing gross injustice or violation of public policy. In this particular case, he did not see any such reasons and therefore felt that Mr.Shurtleff’s rights as an innocent purchaser were being unfairly violated.