In the 1923 case of Davis v. Wolfe, the United States Supreme Court addressed a dispute over land ownership and compensation under the Transportation Act. The plaintiff, Davis, was an agent designated under this act who sought to take possession of certain lands owned by Wolfe for railway purposes. However, Wolfe claimed that he had not been adequately compensated for his property as required by law. The court ruled in favor of Davis stating that while it is true that private property cannot be taken without just compensation being made to its owner; however, such payment need not necessarily precede or accompany the taking process but can follow it instead. Therefore, even though Wolfe had yet to receive full payment at the time when his land was seized for public use (railway construction), this did not constitute a violation of his rights since he would still eventually receive fair monetary compensation.

In the dissenting opinion for Davis, Designated Agent Under The Transportation Act v. Wolfe (1923), Justice McReynolds disagreed with the majority's decision to uphold a lower court ruling that allowed an agent of the federal government to sue on behalf of a railroad company in state court. He argued that this was not permitted under Section 206(a) of the Transportation Act, which he believed only gave such agents authority to sue in federal courts. Furthermore, he contended that allowing suits in state courts could lead to inconsistent rulings and undermine uniformity across jurisdictions - something Congress sought when it passed legislation related to interstate commerce like railroads. In his view, if Congress had intended for these agents to have broader powers including suing in state courts, they would have explicitly stated so within the law itself.