United States v. Rizzinelli 182 Fed. 675 (D.Idaho 1910) Under the General Mining Law of 1872 (30 U.S.C. §22), people were allowed to make claims to "valuable mineral deposits" they found on Federal lands. Once a claim is filed, the Mining Law gives the claimant "the exclusive right of possession and enjoyment of all the surface of their locations." They can also file a patent and get ownership of the land practically free. Rinzinelli made a claim to some lands in a National Forest in Idaho, but instead of mining on the land, he instead used it to build a saloon. Rinzinelli never filed a patent to take title to the lands, they were still owned by the Federal government. The Department of Agriculture (USDA) fined Rinzinelli for running a saloon without a permit. Rinzinelli appealed. Rinzinelli argued that the Mining Law allowed him to "enjoy" the property, and that includes building a saloon, or any other purpose. Rinzinelli pointed out that a lot of other people were using mining claims for a lot of non-mining activities too. USDA argued that "enjoyment" should be limited to things that were directly for mining purposes. The Trial Court found for USDA. The Trial Court noted that Rinzinelli had a distinct but qualified property right in the land, because of the mining claim. The Court found that the Rinzinelli's right to "enjoyment" of the surface is limited to uses incident to mining operations. The Court found that the government still has the property rights to the land for things that aren't mining operations, so if they want to require a permit to build a saloon, they can legally do so. If Rinzinelli had filed a patent, which would have completely transferred title of the land to him, then USDA would have had no say. But he didn't do that.