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The U.S. Supreme Court case Watt, Secretary of the Interior, et al. v. Western Nuclear, Inc., 1982 revolved around a dispute over ownership of gravel found on land owned by Western Nuclear under the Stock-Raising Homestead Act (SRHA) of 1916. The SRHA allowed private citizens to claim federal lands for ranching purposes but reserved mineral rights to the government; however, it was unclear whether "minerals" included gravel in this context. When Western Nuclear began mining and selling gravel from its property without permission from or payment to the federal government, then-Secretary of Interior James G Watt sued for compensation and an injunction against further extraction activities. The Supreme Court ruled in favor of Watt with a majority decision that interpreted "mineral" as inclusive of gravel within SRHA's language and historical context - thus affirming that such resources belonged to the federal government even when located on privately claimed land under this act. This ruling upheld lower court decisions while also setting precedent for future cases involving similar disputes over natural resource ownership.
In the dissenting opinion for Watt, Secretary of the Interior, et al. v. Western Nuclear, Inc., Justice Thurgood Marshall argued that the majority's interpretation of "minerals" in the Stock-Raising Homestead Act was too broad and inconsistent with Congress' intent when passing this legislation. He contended that gravel did not fall under this definition as it is a common substance found everywhere and its extraction does not require mining expertise or equipment like other minerals do. Furthermore, he pointed out that including gravel within this definition could lead to absurd results such as homesteaders losing their rights to soil on their land because it contains small amounts of mineral substances. Thus, he believed that Congress intended only valuable substances requiring special skill and effort to extract be classified as minerals under this act.