In the 1903 case of Charnock v. Texas and Pacific Railway Company, the United States Supreme Court dealt with a dispute over land ownership in Texas. The plaintiff, Charnock, claimed that he had purchased land from an individual who had received it as part of a federal grant to the state of Texas for railway construction purposes. However, this particular parcel was not used for railway construction and was sold by the State to private individuals instead. The defendant company argued that they were entitled to this piece of land under their original charter which granted them every alternate section along their line within certain limits regardless if it was used or unused. The court ruled in favor of Charnock stating that once lands have been certified as part of such grants but are not required or utilized for railroad purposes then they become subject to disposal by the State like any other public lands; thus validating his purchase from previous owners who bought it directly from the State after certification.

The dissenting opinion in the case of Charnock v. Texas and Pacific Railway Company argued that the court majority erred in its interpretation of the law, specifically regarding negligence and liability. The dissent believed that there was sufficient evidence to suggest that the railway company had been negligent in their duty to provide a safe working environment for their employees, including Mr. Charnock who suffered fatal injuries while on duty due to an unsafe condition at his workplace which he wasn't warned about by his employer. They contended that this failure constituted negligence on part of the company, making them liable for damages resulting from such neglectful conduct under existing laws governing employers' responsibilities towards employee safety. Therefore, they disagreed with the majority's decision absolving Texas and Pacific Railway Company from any responsibility or liability related to Mr.Charnock's death.