In the 1906 case of Andrews v. Eastern Oregon Land Company, the U.S Supreme Court was called upon to decide a dispute over land ownership rights. The plaintiff, Andrews, claimed that he had acquired title to certain lands under an Act of Congress passed in 1866 which granted railroad companies right-of-way through public lands and also allowed them to sell portions of these lands for settlement and cultivation. However, before selling any such land, it was necessary for the company to file a map showing its line of road with the Secretary of Interior who would then withdraw from sale or entry all public lands within specified limits on either side of this line until completion or abandonment thereof by said company. The defendant argued that they were entitled to retain possession because they purchased their interest after this process had been completed but before patent issued - during what is known as 'inchoate' period when legal title still remained with government but equitable title vested in railroad company. The court ruled in favor of defendant holding that once approval has been given by Secretary and withdrawal made effective; no subsequent purchaser can acquire superior rights even if actual construction hasn't commenced yet since purpose behind legislation was not just building railroads but also encouraging settlement along those lines hence need for early identification & protection against conflicting claims.

In the dissenting opinion for Andrews v. Eastern Oregon Land Company, Justice Harlan disagreed with the majority's interpretation of the Act of Congress from 1866 and its subsequent amendments in relation to land grants for railroads. He argued that these acts did not intend to grant lands containing valuable minerals to railroad companies, but rather aimed at promoting settlement and development by granting agricultural lands only. According to him, if a tract was known or suspected to contain valuable minerals at the time it was granted, it should have been excluded from such grants under law. Therefore, he believed that Eastern Oregon Land Company had no valid claim over mineral-rich lands merely because they were within odd-numbered sections along their railway line as per their land grant agreement with Congress. The company’s right should be limited only up until where there is proof beyond reasonable doubt about absence of any knowledge regarding presence of precious metals during original allocation.