In the 1904 case of Steigleder v. McQuesten, the United States Supreme Court addressed a dispute over mining rights in Alaska. The plaintiff, Steigleder, claimed that he had been unlawfully dispossessed of his mining claim by the defendant, McQuesten. The court ruled in favor of McQuesten based on evidence showing that Steigleder had abandoned his claim before it was taken up by McQuesten and thus lost any right to it under existing law at that time which required continuous work on a claim to maintain ownership rights. Additionally, there were no signs or notices posted indicating possession when McQuesten took over the property as required by law for maintaining an unattended claim. Therefore, according to these laws governing mineral lands in Alaska during this period (1898), abandonment could be inferred from non-compliance with requirements for maintaining claims.

The dissenting opinion in the case of Steigleder v. McQuesten argued that the majority's decision to uphold a lower court ruling, which held that a mining claim was invalid due to insufficient labor and improvements, was incorrect. The dissenting justices believed that there had been enough work done on the mine to satisfy legal requirements for maintaining ownership of a mining claim under federal law. They also disagreed with the majority's interpretation of what constituted "labor" and "improvements," arguing it should include not just physical changes made directly within or upon the mine itself but also any work indirectly benefiting or facilitating its operation such as building roads leading up to it. Furthermore, they contended that even if there were periods where no active labor occurred, this did not necessarily mean abandonment given various practical reasons might temporarily halt operations without implying an intent by owners to relinquish their rights over said property.