In the 1899 case of Adirondack Railway Company v. New York State, the U.S. Supreme Court ruled in favor of New York State, upholding its right to reclaim land it had previously granted to a railway company for public use as a forest preserve. The state had initially given the Adirondack Railway Company permission to build tracks on this land but later decided that it wanted to convert these lands into a park. The railway company argued that they still held rights over this property and sued the state when it attempted to take back control of these lands. However, the court found that since New York's constitution included provisions allowing for such reclamation in order to protect natural resources and promote recreation, their actions were legal.

The dissenting opinion in the case of Adirondack Railway Company v. New York State argued that the state had no right to appropriate private property for public use without just compensation, even if it was done under the guise of a tax. The justice believed this violated both federal and state constitutions. He also disagreed with the majority's interpretation of "public use," arguing that it should be narrowly defined as something directly used by or beneficial to the public, not simply anything deemed advantageous by lawmakers. Furthermore, he contended that allowing such appropriations would set a dangerous precedent where any private property could potentially be seized under similar circumstances. This view held firm on protecting individual rights against potential government overreach.