In the 1896 case of Wight v. United States, the Supreme Court ruled on a matter concerning land ownership and mining rights in Colorado. The plaintiff, Wight, had purchased land from a railroad company that was originally granted to it by an act of Congress. However, this particular piece of land contained valuable mineral deposits which were discovered after its sale to Wight. Under federal law at that time (the Mining Act), all valuable mineral lands were excluded from such grants made by Congress and reserved for public acquisition through mining claims or other means. The defendant in this case was a miner who staked out a claim on part of the property sold to Wight under provisions set forth in the Mining Act. When sued by Wight for trespassing, he argued his actions were legal due to these provisions. The Supreme Court sided with the miner-defendant stating that even though there may have been no known existence of minerals when initially transferred from government ownership; once their presence became known later on they fell within purview of laws governing public domain lands containing precious metals - thus making them available for claiming under those same laws regardless if someone else owned surface rights above them.

In the dissenting opinion for Wight v. United States, 1896, Justice Harlan argued that the majority's decision to uphold a tax on legacies and distributive shares of personal property was unconstitutional. He contended that this tax was not an excise or duty but rather a direct tax on property after death, which should be apportioned among states according to their population as required by Article I Section 9 of the Constitution. In his view, allowing such taxation would open up possibilities for federal interference in state matters and could lead to unequal distribution of taxes among citizens depending upon their location or circumstances at death. Furthermore, he believed it violated principles of uniformity since only those who died possessed were subject to it while others escaped entirely from its burden.