In the 1891 case of Glaspell v. Northern Pacific Railroad Company, the U.S Supreme Court ruled in favor of the defendant, Northern Pacific Railroad Company. The plaintiff, Glaspell had purchased land from a railroad company that was granted to it by an act of Congress and later discovered that there were pre-existing mining claims on this property. He sued for damages claiming he had been sold defective title to the lands because they were subject to these prior unpatented mining claims which rendered his title worthless. However, the court held that since those who made these mining claims did not follow through with procedures required by law such as filing their claim with Land Office or performing annual labor on them; hence they lost any rights associated with their initial discovery and possession. Therefore, when Northern Pacific received its patent from government all previous informal rights including those claimed by miners ceased to exist making its title valid and absolute.

In the dissenting opinion for Glaspell v. Northern Pacific Railroad Company, it was argued that the majority misinterpreted the law and failed to consider important factors in their decision-making process. The dissenting justices believed that Mr. Glaspell had a valid claim against Northern Pacific Railroad Company because he was not adequately warned about potential dangers associated with his work duties, which led to his injury on company property. They felt that employers should be held responsible for ensuring worker safety and providing adequate warnings about possible hazards related to their job tasks. Furthermore, they disagreed with the majority's interpretation of contributory negligence laws and believed these laws should not absolve companies from liability when they fail to provide safe working conditions or proper warning of risks involved in performing certain tasks at work.