The U.S. Supreme Court case Convers v. Atchison, Topeka and Santa Fe Railroad Company in 1891 revolved around a dispute over land rights. The plaintiff, Convers, claimed that he had purchased the land from an individual who received it through a Mexican grant before California became part of the United States. He argued that this made his claim superior to any subsequent grants or sales by the U.S government under its public-land laws. On the other hand, defendant railroad company asserted ownership based on a Congressional Act granting lands for railway construction purposes. The court ruled in favor of Atchison, Topeka and Santa Fe Railroad Company stating that when California was admitted into Union as a state in 1850; all unappropriated public lands within its borders were transferred to federal control regardless of prior Spanish or Mexican grants unless those claims had been presented and confirmed under procedures established by Congress after acquiring territory from Mexico.

In the dissenting opinion for Convers v. Atchison, Topeka and Santa Fe Railroad Company, the justice argued that the majority's decision was a departure from established legal principles regarding liability in tort law. The justice contended that under traditional common law rules, a party is only liable for harm caused by their own negligence or wrongdoing. In this case, however, the railroad company was held responsible for damages resulting from an accident involving one of its trains even though there was no evidence to suggest any fault on part of the company itself. The dissenting judge believed this ruling set a dangerous precedent as it effectively shifted responsibility away from those directly involved in causing harm and onto third parties who merely provided some form of involvement or connection to events leading up to an incident.