In the case of United States on the Relation of Alaska Smokeless Coal Company v. Lane, Secretary of the Interior, et al., 1919, the Supreme Court dealt with a dispute over coal mining rights in Alaska. The plaintiff was an Alaskan coal company that had applied for patents to mine certain lands under laws passed by Congress in 1904 and 1907. However, their applications were rejected by Secretary Franklin K. Lane based on a presidential order from President Taft which withdrew these lands from private exploitation due to concerns about monopolistic control over resources. The court ruled against the coal company stating that while they may have been entitled to apply for patents under previous legislation, this did not guarantee them approval or immunity from subsequent executive orders or changes in policy aimed at protecting public interests.

In the dissenting opinion for the case of United States on the Relation of Alaska Smokeless Coal Company v. Lane, Secretary of Interior et al., it was argued that there were errors in judgment regarding land classification and rights to coal deposits. The dissenting justices believed that when a claimant has complied with all legal requirements necessary to establish their right to a tract of land, they should be entitled not only to surface rights but also any subsurface mineral resources found therein. They contended that this principle had been upheld by previous court decisions and should have been applied in this case as well. Furthermore, they disagreed with the majority's interpretation of certain provisions within mining laws which led them to conclude otherwise. In essence, these justices felt that once an individual or entity legally secures ownership over a piece of property through compliance with existing regulations, they are entitled full possession - including any valuable minerals beneath its surface.