In the case of Germania Iron Company v. United States in 1896, the Supreme Court ruled on a dispute over land patents issued by the U.S. government to railroad companies under an act passed in 1862. The Germania Iron Company claimed ownership of certain lands based on these patents, which were later declared void due to errors made during their issuance process. The company argued that it had purchased and improved upon this land with good faith belief that they held valid title from the railroad companies who received them from federal grants. The court decided against Germania Iron Company stating that even though they may have acted in good faith, it did not change the fact that original titles were invalid as per law and therefore could not be transferred legitimately to subsequent buyers like themselves. Furthermore, since these lands belonged originally to public domain before being erroneously patented out by government officials without authority or jurisdiction over such matters; any improvements made thereon would also belong back into public hands once those mistakes are corrected through annulment proceedings at courts.

In the dissenting opinion for Germania Iron Company v. United States, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and interpretations of the law. He contended that a tax on dividends should not be considered an income tax but rather a direct tax on property, which would require apportionment among states according to population under Article I, Section 9 of the Constitution. Furthermore, he disagreed with the majority's interpretation of Pollock v. Farmers' Loan & Trust Co., asserting it did not establish precedent for taxing dividends as income without apportionment. Lastly, he believed this ruling could lead to potential abuses by allowing Congress to levy taxes arbitrarily and disproportionately across different types of property or wealth.