In the case of United States ex rel. Arant v. Lane, Secretary of the Interior in 1917, the Supreme Court ruled on a dispute regarding land rights under an irrigation project authorized by Congress through the Reclamation Act of 1902. The plaintiff, Arant, claimed that he had been unlawfully deprived of his water rights and property without due process after being excluded from a list determining who could receive water from an irrigation project in Nevada's Truckee-Carson area. He sought to compel Franklin K. Lane (the then-Secretary of Interior) to include him on this list. The court held that it did not have jurisdiction over such administrative decisions made by executive officers like Secretary Lane unless there was clear evidence they acted beyond their authority or violated constitutional rights - neither condition met here according to them. They further stated that while individuals may have certain vested interests in public lands or resources based on state law; these are subject to Congressional power when dealing with matters related to federal reclamation projects as per Property Clause (Article Four) and Commerce Clause (Article One). Thus affirming lower courts' dismissal for lack of jurisdiction.

In the dissenting opinion for United States ex rel. Arant v. Lane, Justice Holmes argued that the Secretary of Interior had no authority to review decisions made by the Commissioner of Indian Affairs after a year had passed. He believed this was an overreach of power and not within his jurisdiction as outlined in federal law. Furthermore, he contended that such actions could potentially disrupt settled matters and create uncertainty within administrative processes if left unchecked. In essence, Justice Holmes' dissent focused on maintaining clear boundaries between different levels of decision-making authorities to ensure efficient governance and uphold legal certainty.