In the case of St. Louis Mining and Milling Company v. Montana Mining Company, 1898, the U.S Supreme Court was tasked with resolving a dispute over mining rights in Montana between two companies: The St. Louis Mining and Milling Company (St.Louis Co.) and the Montana Mining Company (Montana Co.). Both companies claimed ownership to certain sections of land containing valuable mineral deposits based on different interpretations of federal mining laws. The main issue at hand was whether or not "extralateral rights" applied - this principle allows miners to follow veins of ore even if they extend outside their vertical boundaries under ground level as long as it originates within their claim's surface boundaries. St.Louis Co., who owned an older claim, argued that extralateral rights allowed them access to these minerals while Montana Co., who had later acquired adjacent property above where these veins extended, disagreed. The court ruled in favor of St.Louis Co., upholding the doctrine of extralateral rights which meant that any vein originating within one’s property could be followed and mined wherever it led underground regardless if it extends into another person's surface estate.

In the dissenting opinion for St. Louis Mining and Milling Company v. Montana Mining Company, the justice argued that the majority's decision was flawed because it failed to properly consider established principles of equity jurisprudence. The justice contended that a court of equity should not have granted relief to a party who had been aware of an ongoing trespass on their property but did nothing about it for several years, thereby allowing another party to invest heavily in improving said property under good faith belief they were its rightful owners. In such cases, he believed laches (unreasonable delay) should apply as defense against claims made by original owner seeking recovery or compensation for improvements made by innocent encroachers during period of neglectful silence from true owner. He also disagreed with majority’s interpretation regarding mining laws and rights related thereto; arguing instead that these laws intended miners be given reasonable opportunity to extract minerals without fear of litigation if they acted in good faith based on best available information at time.