In the 1895 case Beebe v. United States, the Supreme Court ruled on a dispute regarding land patents in Arkansas. The plaintiff, Beebe, had purchased lands at a public sale that were part of an indemnity to railroads under Congressional acts from 1866 and 1870. However, these lands were later patented by the government to another party who claimed them as swamp lands granted under an act from 1850. The court held that once land has been identified as falling within railroad limits for purposes of granting indemnity rights (as it was when sold to Beebe), it cannot be subsequently classified as swamp land and given away by patent without violating those pre-existing rights. Therefore, even though there may have been errors in identifying or classifying such lands initially, this did not affect their status with respect to subsequent grants or patents issued by the government.

In the dissenting opinion for Beebe v. United States, it was argued that the government did not have a valid claim to land granted by Congress under an 1866 statute because it failed to fulfill its obligation within three years as required by law. The dissenting justices believed that the majority's interpretation of this law was incorrect and overly broad, allowing the government too much leeway in claiming lands long after they should have been made available for public use or private ownership. They contended that such a reading of the statute would undermine its original intent and could potentially lead to abuses of power by future administrations seeking to control vast amounts of territory without proper justification or legal authority.