In the case of Doyle v. Union Pacific Railway Company, 1892, the U.S Supreme Court ruled in favor of Union Pacific Railway Company. The plaintiff, Mr. Doyle had purchased land from a railroad company that was granted to it by an Act of Congress in 1862 for constructing a transcontinental railway line. Later on, he discovered coal on this property and claimed ownership over it as well. However, the court held that under the terms of the grant made by Congress to aid in building railroads across public lands did not include minerals such as coal or iron found beneath those lands unless expressly stated otherwise within said grant's language - which wasn't present here; thus these remained federal property even after surface rights were transferred to private parties like Mr.Doyle who bought them from original grantees (railroad companies). Therefore his claim was dismissed and mineral rights stayed with government.

In the dissenting opinion for Doyle v. Union Pacific Railway Company, it was argued that the plaintiff should not be barred from recovery due to contributory negligence because he had no knowledge of the danger posed by his actions. The justice believed that while Doyle may have been negligent in leaving his horses unattended near a railway track, this did not necessarily mean he contributed to their death as there was no evidence suggesting he knew or ought to have known about the risk involved. Furthermore, it was pointed out that even if Doyle's actions were deemed negligent and contributing factors to the accident, they would only reduce but not eliminate his right to damages under comparative negligence law which allows a partially responsible party still recover some damages proportionate with their degree of fault.