The U.S. Supreme Court case Work, Secretary of the Interior v. United States ex rel. Rives in 1924 revolved around a dispute over land ownership rights under the Stock-Raising Homestead Act of 1916 (SRHA). The SRHA allowed individuals to claim up to 640 acres of public lands for ranching purposes but reserved mineral rights to the government. In this case, an individual named Rives claimed that he had discovered oil on his homesteaded land and argued that he should be entitled to these resources as they were not specifically mentioned in the SRHA's reservation clause. The court ruled against Rives, stating that while it was true oil was not explicitly listed among reserved minerals in the act, it fell within its scope because petroleum is commonly understood as a mineral resource. Therefore, even though surface owners have exclusive right over their property for farming or grazing purposes under SRHA provisions, subsurface minerals including oil belong exclusively to federal government.

In the dissenting opinion for Work, Secretary of the Interior v. United States ex rel. Rives, Justice McReynolds disagreed with the majority's decision to uphold a lower court ruling that ordered Secretary of Interior Hubert Work to issue oil leases on public lands in California and Wyoming. He argued that this case was not about whether or not these leases should be issued but rather who had the authority to make such decisions - Congress or courts? According to him, it was clear from legislation passed by Congress that they intended for such matters concerning public lands and resources therein like oil deposits were meant solely under executive control through departments like Interior Department headed by its secretary. Therefore he believed it improper for judiciary branch (courts) to interfere in what is essentially an administrative matter unless there are allegations of fraud or illegality which wasn't present here.