In the 1906 case of Wyoming ex rel. Wyoming Agricultural College v. Irvine, Treasurer of the State of Wyoming, the Supreme Court was asked to determine whether a state law that diverted funds from land grants intended for agricultural colleges violated federal law. The Morrill Act had granted lands to states for establishing colleges focused on agriculture and mechanical arts; however, a subsequent state law in Wyoming redirected some income generated by these lands towards public schools instead. The court ruled that this redirection did not violate federal laws as long as it didn't interfere with or diminish the college's ability to function effectively in its designated role under the Morrill Act provisions. Therefore, while states were given considerable discretion over how they used their land grant resources, they could not undermine or compromise federally mandated educational objectives.

In the dissenting opinion for Wyoming Agricultural College v. Irvine, it was argued that the majority's decision to uphold a state law diverting funds from the college to other uses violated both federal and state laws. The dissent pointed out that under federal law, these funds were specifically granted to support agricultural colleges and could not be used for any other purpose. Furthermore, they noted that this diversion of funds also violated Wyoming's own constitution which required all such grants to be faithfully applied towards their intended use. Therefore, in their view, by allowing this misappropriation of funds without legal consequence or remedy effectively undermined both federal authority and constitutional safeguards against misuse of public resources.