The U.S. Supreme Court case Work, Secretary of the Interior v. United States ex rel. Chestatee Pyrites & Chemical Corporation in 1924 revolved around a dispute over mining rights on public lands under the Mining Act of 1872. The Chestatee Pyrites & Chemical Corporation had filed for mineral land patents with the Department of Interior but was denied by Secretary Work who argued that pyrite did not qualify as a valuable mineral deposit under the act's provisions and thus could not be patented. The corporation challenged this decision, leading to court proceedings where it was ruled that pyrite does indeed constitute a valuable mineral deposit due to its commercial value and usage in industries such as agriculture and manufacturing sulfuric acid, thereby qualifying it for patenting according to law stipulations at that time.

In the dissenting opinion for Work, Secretary of the Interior v. United States ex rel. Chestatee Pyrites & Chemical Corporation, Justice Holmes argued against the majority's interpretation of mining law and its application to this case. He contended that under existing legislation, a claimant who discovered valuable mineral deposits on public land had an exclusive right to possession and enjoyment until patent was issued or denied by federal authorities. In his view, this principle should apply regardless of whether the minerals were found in lodes or placers (surface deposits). The majority held that only lode discoveries conferred such rights while placer claims did not unless they contained precious metals like gold or silver - which pyrite is not considered as one. Holmes disagreed with this distinction between types of mineral deposits and believed it contradicted established precedent regarding mining rights on public lands.