In the Smale v. Mitchell case of 1891, the U.S Supreme Court ruled on a dispute involving mining rights in Idaho. The plaintiff, John Smale, claimed that he had been unlawfully dispossessed of his mining claim by defendant James Mitchell and sought restitution for profits lost during this period. However, the court found that Smale's original claim to the mine was invalid because it did not comply with federal law requiring all mineral deposits to be properly recorded at a local land office before any work could commence. As such, when Mitchell began working on what he believed was unclaimed land and subsequently registered it under his name at a local land office as required by law; he became its lawful owner despite Smale's prior but improperly documented use of it. Therefore, while acknowledging that both parties acted in good faith believing they were rightful owners of the mine due to conflicting state and federal laws regarding property claims; Justice Samuel Blatchford delivered an opinion affirming lower courts' decisions favoring Mitchell based on compliance with federal statutes governing acquisition of public lands containing valuable minerals.

In the dissenting opinion for Smale v. Mitchell, it was argued that the majority's decision to uphold a lower court ruling in favor of Mitchell failed to properly consider key aspects of contract law and property rights. The dissenting justices believed that Smale had not been given adequate opportunity to present evidence supporting his claim over certain mining properties, which he alleged were unlawfully seized by Mitchell. They contended that the majority's interpretation of relevant statutes was overly narrow and did not fully account for broader principles related to equity and fairness. Furthermore, they disagreed with the majority’s view on how mining claims should be treated under federal law, arguing instead for a more expansive understanding that would better protect individual miners' rights against potential abuses by larger corporate interests.