The U.S. Supreme Court case Farmers' Loan and Trust Company v. Chicago, Portage and Superior Railway Company and Chicago, St. Paul, Minneapolis and Omaha Railway Company in 1895 revolved around a dispute over the foreclosure of a mortgage on railway property. The Farmers' Loan & Trust Co., as trustee for bondholders under the mortgage deed of trust, sought to foreclose due to default by the railway companies involved. The main issue was whether certain lands were included in this mortgage or not; these lands had been granted by Congress to aid in construction but hadn't been specifically mentioned in the original agreement between parties involved. The court ruled that despite their omission from explicit mention within the contract's text, these lands were indeed part of what was mortgaged because they fell within its general description - being part of 'all properties owned or thereafter acquired'. This decision upheld an earlier ruling made by lower courts which confirmed that such broad language used when describing assets covered all real estate holdings including those gained through Congressional land grants.

The dissenting opinion in the case of Farmers' Loan and Trust Company v. Chicago, Portage and Superior Railway Company and Chicago, St. Paul, Minneapolis and Omaha Railway Company argued that the majority's decision to allow a mortgagee to foreclose on a mortgaged property without first paying off any outstanding liens was incorrect. The dissent believed this ruling violated established principles of equity jurisprudence which dictate that all parties with an interest in a property should be made whole before any one party can claim sole ownership through foreclosure proceedings. They contended that allowing such actions would unfairly disadvantage junior lienholders who may not have had sufficient opportunity or resources to protect their interests during foreclosure proceedings.