In the case of Beaupre v. Noyes (1890), the U.S Supreme Court was tasked with determining whether a lower court had jurisdiction over a dispute involving land in Dakota Territory, which at that time was not yet divided into North and South Dakota states. The plaintiff, Beaupre, claimed ownership of certain lands under preemption rights granted by Congress to settlers on public lands. However, these claims were contested by Noyes who argued that he held valid title deeds for those same lands from railroad companies to whom Congress had previously granted them as part of an effort to encourage westward expansion and development. The Supreme Court ruled in favor of Noyes stating that once Congress grants land it cannot be reclaimed or preempted unless explicitly stated otherwise in law or if there is evidence proving fraud or mistake during its disposal process.

In the dissenting opinion for Beaupre v. Noyes, it was argued that the majority's decision to uphold a lower court ruling in favor of Noyes was incorrect due to an improper interpretation of law and precedent. The dissenting justices believed that the plaintiff, Beaupre, had a valid claim against Noyes based on their understanding of property rights and contract law. They contended that the original agreement between both parties should have been honored as per its terms rather than being subjected to reinterpretation by subsequent courts. Furthermore, they disagreed with how evidence was evaluated in this case and felt there were inconsistencies in applying legal principles which led to an unjust outcome for Beaupre.