In the case of United States ex rel. Champion Lumber Company v. Fisher, Secretary of the Interior in 1912, the Supreme Court was asked to determine whether a lumber company had valid claims on timberland under an act that allowed for purchase and settlement by private citizens. The Champion Lumber Company argued they were entitled to these lands due to their improvements made upon them such as building roads and other infrastructure necessary for logging operations. However, the Secretary of Interior disagreed with this interpretation and denied their claim. The Supreme Court sided with the Secretary of Interior stating that while it is true that certain acts allow private individuals or corporations to acquire public land through improvement or cultivation, this does not apply when those activities are conducted primarily for commercial exploitation rather than genuine settlement purposes. In essence, because Champion's primary intent was commercial profit rather than creating a homestead or permanent residence on these lands as required by law at that time; they did not have a legitimate claim over them.

In the dissenting opinion for United States ex rel. Champion Lumber Company v. Fisher, it was argued that the Secretary of Interior lacked authority to cancel a land patent after its issuance by the government without judicial proceedings. The dissenting justices believed that once a patent is issued, it becomes incontrovertible evidence of legal title and can only be annulled through appropriate court action. They contended that allowing an administrative officer such as the Secretary of Interior to unilaterally cancel patents would undermine property rights and violate due process protections under law. Furthermore, they disagreed with majority's interpretation of relevant statutes governing land patents, arguing these laws did not grant any implied power to administratively revoke them post-issuance.