In the case of Benedict v. United States in 1899, the Supreme Court ruled on a dispute over a contract for mail delivery services between New York and Boston. The plaintiff, William E. Benedict, had entered into an agreement with the U.S government to provide this service at a rate of $4 per mile annually but later sought additional compensation based on his interpretation that he was entitled to payment per trip rather than per mile. The court disagreed with Benedict's interpretation and held that he was only entitled to be paid according to the original terms of his contract - i.e., $4 per mile annually regardless of how many trips were made during that year.

In the dissenting opinion for Benedict v. United States, Justice Harlan argued that the government had no right to seize property from a private citizen without due process of law. He believed that this seizure was in violation of the Fifth Amendment, which protects citizens from being deprived of their property without just compensation. Furthermore, he disagreed with the majority's interpretation of "public use," arguing that it should be strictly limited to cases where the public directly benefits from or uses seized property. In his view, seizing land for resale did not meet this criterion and thus constituted an abuse of eminent domain powers by Congress.