In the case of Duluth and Iron Range Railroad Company v. Roy, 1898, the U.S. Supreme Court ruled in favor of the railroad company. The dispute arose when Mr. Roy claimed that his land was wrongfully taken by the Duluth and Iron Range Railroad Company under an act granting lands to aid in construction of railroads in Minnesota passed by Congress on March 3, 1857. However, it was found that at the time this act came into effect, Mr.Roy's land had not yet been surveyed officially as required for such claims to be valid under federal law; thus he did not have a legal claim to it until after its official survey which occurred later than when railroad received their grant from Congress (1875). Therefore,the court held that since Mr.Roy's claim wasn't legally recognized at time when railroad got their grant,his subsequent acquisition couldn't affect rights already vested with them.The decision reaffirmed principle that unsurveyed public lands are part of public domain & subject to disposal by government without any private interference.

In the dissenting opinion for Duluth and Iron Range Railroad Company v. Roy, Justice Harlan disagreed with the majority's interpretation of Minnesota state law regarding taxation of iron ore lands. He argued that under Minnesota law, all property should be taxed equally and uniformly without any special privileges or immunities to certain properties or individuals. In his view, the statute in question did not exempt mining companies from paying taxes on their mineral rights but rather provided a method for assessing those rights separately from surface land values. Therefore, he believed that the railroad company was liable for taxes on its mineral interests just like any other property owner in the state would be. Furthermore, he contended that even if there were ambiguity about this point in state law, it was up to Minnesota courts – not federal ones – to interpret such matters.