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Wasatch Mining Company v. Crescent Mining Company

• 1892 • 148 U.S. 293 • Fuller Court
In the case of Wasatch Mining Company v. Crescent Mining Company in 1892, the U.S Supreme Court was tasked with resolving a dispute over mining rights. The Wasatch Mining Company claimed that it had acquired ownership of certain mineral veins or lodes within its mining claim under the General Mining Act of 1872 and accused Crescent Mining Company of trespassing on their property and extracting ores from these veins unlawfully. However, Crescent argued that they held rightful ownership to these...Open Case
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Chief Fuller Court
Term: 1892
Docket: 135
148 U.S. 293
13 S. Ct. 600
37 L. Ed. 454
1893 U.S. LEXIS 2232
Argued: Mar 13, 1893

Wasatch Mining Company v. Crescent Mining Company

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Opinion Summary
AI Abstract

In the case of Wasatch Mining Company v. Crescent Mining Company in 1892, the U.S Supreme Court was tasked with resolving a dispute over mining rights. The Wasatch Mining Company claimed that it had acquired ownership of certain mineral veins or lodes within its mining claim under the General Mining Act of 1872 and accused Crescent Mining Company of trespassing on their property and extracting ores from these veins unlawfully. However, Crescent argued that they held rightful ownership to these minerals as per their own patented land claims which were granted earlier than those of Wasatch's. The court ruled in favor of Crescent stating that according to law, when two mines intersected at an angle underground, each mine owner retained rights only up until the point where it met another’s claim line extended vertically downward (the apex rule). Since all disputed veins apexed outside Wasatch's surface boundaries but inside Crescents', they belonged to Crescent despite running into Wasatch's territory below ground level. This ruling reinforced adherence to established principles governing subterranean property rights while also emphasizing careful consideration for patent dates when determining legal entitlements.

Dissent Summary
AI Abstract

In the dissenting opinion for Wasatch Mining Company v. Crescent Mining Company, the justice argued that there was a lack of substantial evidence to support the majority's decision. The justice believed that it was not proven beyond reasonable doubt that Wasatch had intentionally and knowingly trespassed on Crescent’s mining claim with malicious intent. He also disagreed with how damages were calculated, arguing they should be based on actual harm done rather than potential profits lost by Crescent due to alleged trespassing activities by Wasatch. Furthermore, he expressed concern over what he perceived as an unfair bias towards large corporations in legal disputes involving property rights against smaller entities or individuals. This case set a precedent which could potentially encourage larger companies to infringe upon others' rights without fear of significant financial repercussions if their actions are deemed unintentional or non-malicious.

Opinion written by Justice GShiras
Decided: Mar 27, 1893
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