In the United States v. Gorham case of 1896, the Supreme Court ruled on a dispute involving land patents and mining claims in California. The plaintiff, the U.S government, contested that it had mistakenly issued a patent to defendant Gorham for land containing valuable mineral deposits which should have been classified as 'mineral lands' exempt from sale or grant by federal law. However, Gorham argued that at the time of his application and subsequent granting of patent rights in 1874, no known valuable mineral deposits existed on this property; hence it was not 'mineral land'. The court sided with Gorham stating that if at the time when he applied for purchase there were no known minerals upon it making it valuable for mining purposes then such lands are not "known" mines even though they may afterwards be discovered to contain minerals. Therefore, since there was no evidence showing knowledge about existence of any mine before issuing him title deed (patent), he could retain ownership over said property despite later discovery of its value due to presence of minerals.

The dissenting opinion in the United States v. Gorham case was not available or recorded, as it is common with many older Supreme Court cases. The court's decision was unanimous and therefore no dissenting opinion exists for this particular case.