In the case of Simmons v. Swan in 1927, the United States Supreme Court ruled on a dispute involving land ownership and mineral rights. The plaintiff, Simmons, claimed that he had purchased land from Swan with an agreement that any minerals found would be shared equally between them. However, when oil was discovered on the property years later, Swan refused to honor this agreement and asserted sole ownership over all profits derived from it. The court sided with Simmons stating that although there was no written contract regarding their arrangement about sharing mineral rights at the time of purchase; oral agreements were binding under Oklahoma law where the property is located if they could be proven by clear evidence which existed in this case through testimonies of witnesses who heard their conversation about splitting potential future profits from minerals evenly.

In the dissenting opinion for Simmons v. Swan, Justice Stone argued that the majority's decision to uphold a state law prohibiting out-of-state corporations from owning land in Florida was inconsistent with previous Supreme Court rulings and violated the Commerce Clause of the U.S. Constitution. He contended that this ruling effectively allowed states to discriminate against interstate commerce by preventing non-resident businesses from acquiring property necessary for their operations within a given state. Furthermore, he asserted that such laws could potentially lead to retaliatory legislation among states, thereby undermining national unity and economic integration. In his view, it is not within a state’s power to restrict or control business activities of foreign corporations which are essentially part of interstate commerce.