In the United States v. Rowell et al., 1916, the Supreme Court examined whether a federal law prohibiting mail fraud could be applied to fraudulent schemes involving oil leases on public lands. The defendants were charged with using the U.S Postal Service to defraud investors by selling them worthless oil leases on government land in Wyoming and Montana. They argued that they couldn't be prosecuted under this law because their scheme involved public land, which was not "property" as defined by the statute. The Supreme Court disagreed with this argument and upheld their convictions. It ruled that while it's true that public lands are not private property, they still have value and can therefore be subject of fraud within meaning of postal laws against such conduct. This case expanded interpretation of what constitutes "property" under federal mail fraud statutes.

The dissenting opinion in the United States v. Rowell et al., 1916 case argued that the majority's decision to uphold a conviction for conspiracy to defraud the U.S. government was flawed due to lack of evidence proving intent. The dissenters believed that while there may have been irregularities and negligence on part of defendants, it did not necessarily constitute an intentional fraud against the government. They pointed out that no direct proof was presented showing any agreement between defendants with fraudulent intentions or actions leading towards such ends, which is essential for a conspiracy charge. Furthermore, they contended that mere failure by officials to perform their duties properly does not automatically imply criminality unless malicious intent can be proven beyond reasonable doubt.