In the United States v. Midwest Oil Company case of 1914, the U.S. Supreme Court ruled in favor of a presidential implied power to protect public lands from exploitation and damage, even if Congress had not explicitly granted such authority. The dispute began when President Taft issued an executive order prohibiting oil drilling on public land without approval from the Secretary of Interior Department. Midwest Oil Company violated this order and was sued by the government for trespassing on federal property. The company argued that there were no statutory laws granting presidents such powers over public lands; however, their argument was rejected by both lower courts and eventually by the Supreme Court as well. In its decision, the court cited historical precedent where past presidents had exercised similar control over public lands without explicit congressional authorization - effectively establishing a tradition or "implied" power now recognized as law.

The dissenting opinion in the United States v. Midwest Oil Company case argued that the President did not have inherent executive power to withdraw public lands from private acquisition without express congressional authorization. The dissenters believed that such a broad interpretation of presidential authority was inconsistent with constitutional principles of separation of powers and checks and balances, which require legislative approval for significant policy decisions affecting property rights. They contended that by allowing the President to unilaterally set aside public lands, the majority effectively gave him lawmaking powers reserved for Congress under Article I of the Constitution. This view maintained an emphasis on strict adherence to statutory language and expressed concern about expanding executive discretion at the expense of legislative control over public land policy.