In the Bardon v. Northern Pacific Railroad Company case of 1891, the U.S. Supreme Court ruled in favor of the Northern Pacific Railroad Company, dismissing a suit brought against it by Bardon and others who claimed that they had been unfairly deprived of their land rights due to an act passed by Congress in 1864 granting large tracts of public lands to aid in building a railroad from Lake Superior to Puget Sound on the Pacific Coast. The plaintiffs argued that this grant was unconstitutional because it violated their right to equal protection under law as guaranteed by the Fourteenth Amendment. However, Justice Samuel Blatchford delivered an opinion for a unanimous court stating that Congress has broad power over public lands and can dispose them as it sees fit without violating any constitutional provision or principle. Therefore, he concluded that there was no merit in plaintiff's claim and dismissed their suit.

In the dissenting opinion for Bardon v. Northern Pacific Railroad Company, the justice disagreed with the majority's interpretation of a federal statute that granted land to railroad companies. The justice argued that Congress intended to grant only alternate sections of public lands along proposed railroads, not all public lands within certain boundaries as interpreted by the majority. He pointed out inconsistencies in how similar statutes had been interpreted and applied in previous cases, suggesting an arbitrary application of law. Furthermore, he contended that such broad interpretation could lead to unjust enrichment of railroad companies at taxpayers' expense and potentially encourage fraudulent practices among them. Therefore, he believed it was necessary to strictly interpret congressional grants according to their explicit terms rather than extending them beyond what was clearly stated by lawmakers.