In the United States et al. v. Champlin Refining Co., 1950, the Supreme Court ruled on a dispute over oil and gas leases on public lands in Wyoming. The government had cancelled Champlin's lease due to noncompliance with certain regulations, but Champlin argued that these cancellations were invalid because they did not comply with procedural requirements of notice and hearing under the Administrative Procedure Act (APA). The Supreme Court held that APA was not applicable as it does not apply to matters where statutes pre-date its enactment unless there is a subsequent statute which makes it applicable or if Congress intended for such application. In this case, no such intent could be found from Congress nor any subsequent legislation making APA applicable to oil and gas leases cancellation proceedings under existing laws at that time.

In the dissenting opinion for United States et al. v. Champlin Refining Co., Justice Frankfurter disagreed with the majority's decision to reverse and remand the case back to a lower court, arguing that there was no justification for such action based on existing legal principles or precedents. He contended that this move would only serve to prolong litigation unnecessarily without providing any substantial benefits in terms of justice or fairness. Furthermore, he criticized his colleagues' interpretation of relevant statutes and regulations as overly broad and inconsistent with their original intent, suggesting instead a more narrow reading that would uphold previous rulings against Champlin Refining Co. In essence, Justice Frankfurter believed that the Supreme Court had overstepped its bounds by intervening in what should have been a straightforward application of established law.