In the case of Chicago, Santa Fe and California Railroad Company v. Price in 1890, the U.S Supreme Court ruled on a dispute over land grants given to railroad companies by Congress. The plaintiff, Price, claimed that he had purchased part of this land from an individual who had received it as a military bounty grant before it was granted to the railroad company. However, the court found that at no point did this individual have legal title to sell because his claim was based on an invalid Mexican grant which was never confirmed by Congress or any other competent authority. Therefore, when Congress later granted these lands to railroads for construction purposes they were still public lands and could be legally conveyed by government patent without interference from prior claims such as those made by Price's predecessor-in-interest. As a result of these findings, judgment was rendered in favor of Chicago, Santa Fe & California Railroad Company.

In the dissenting opinion for the case of Chicago, Santa Fe and California Railroad Company v. Price, it was argued that the majority's decision to uphold a Kansas statute regulating railroad rates went against previous Supreme Court rulings on similar issues. The dissenting justices believed that this law violated the Fourteenth Amendment by depriving railroads of their property without due process of law. They contended that while states have power to regulate businesses within their borders, they cannot do so in a way that interferes with interstate commerce or infringes upon rights protected by federal law. In this case, they felt that setting maximum rates for rail services constituted an unreasonable seizure of property because it did not allow companies to set prices based on market conditions or operational costs. This view held economic regulation should be left largely to private enterprise under free-market principles rather than government intervention.