United States v. Coleman

Coleman (defendant) discovered common quartzite stone on federal land in California and applied for a land patent, claiming it was a valuable mineral deposit under the General Mining Law of 1872. The Secretary of the Interior denied the application because quartzite failed the 'marketability test' -- it couldn't be extracted and sold at a profit -- and the government sued to eject Coleman from the land. The district court ruled for the government, but the court of appeals reversed, reasoning the marketability test was more demanding than the traditional 'prudent-man test' for evaluating mineral claims. The Supreme Court granted certiorari, with the government also questioning Coleman's motives, noting he had built a home on the land, quartzite had no real market, and identical stone was abundant elsewhere.