In the United States v. Perkins case of 1895, the Supreme Court ruled on a dispute regarding land patents and mining rights in Colorado. The defendant, Perkins, had obtained a patent for his land that included valuable mineral deposits. However, these minerals were discovered after he received his patent and thus were not mentioned in it. The U.S government argued that since the patent did not explicitly grant him ownership of these minerals, they remained federal property. The court disagreed with this argument and sided with Perkins. It held that when an individual receives a land patent from the government without any reservations or exceptions stated within it - as was true in this case - then all rights to everything on or beneath said lands are transferred to them by default unless otherwise specified by law at time of transfer. This decision reinforced private property rights under American law while also setting precedent for future cases involving similar disputes over natural resources found on privately owned lands post-patent issuance.

In the dissenting opinion for United States v. Perkins, Justice Harlan disagreed with the majority's decision to uphold a lower court ruling that allowed a naval officer to be demoted without trial by court-martial. He argued that this violated Article II of the Constitution which states that "The President shall be Commander in Chief of the Army and Navy of the United States." According to Justice Harlan, this clause should not allow for arbitrary dismissals or reductions in rank without due process. Instead, he believed it was intended only to establish civilian control over military forces during times of war or national emergency. Furthermore, he contended that Congress did not have authority under its constitutional power “to make Rules for the Government and Regulation of land and naval Forces” to authorize such actions either because they would infrally upon individual rights protected by other provisions in Constitution like Fifth Amendment’s guarantee against deprivation “of life, liberty or property without due process.” Thus according his interpretation any law allowing such action is unconstitutional as well as any executive order implementing it.