The Great Northern Railway Company v. United States case in 1927 revolved around the interpretation of a federal statute regarding land grants to railroad companies. The U.S. government had previously granted certain lands to the railway company for building rail lines, but it was unclear whether this grant included rights to minerals beneath the surface of these lands. The Supreme Court ruled that such mineral rights were not included in the original grant and remained with the U.S government, as they were not explicitly mentioned or necessary for construction and operation of railways. This decision established an important precedent in American property law by clarifying that unless specifically stated otherwise, sub-surface mineral rights are separate from surface land ownership.

In the dissenting opinion for Great Northern Railway Company v. United States, Justice McReynolds disagreed with the majority's interpretation of the Hepburn Act and its application to this case. He argued that Congress did not intend for railroads to be held responsible for damages caused by fires started unintentionally or without negligence on their part. The justice believed that such an interpretation was unreasonable and would place an undue burden on railroad companies, potentially leading to unjust outcomes. Furthermore, he contended that if Congress had intended such a result, it would have explicitly stated so in clear terms within the legislation itself rather than leaving it open to judicial interpretation.