In the 1914 case of Greenleaf Johnson Lumber Company v. Garrison, Secretary of War, the lumber company filed a suit against Lindley M. Garrison, who was serving as the U.S. Secretary of War at that time. The lawsuit arose from a dispute over land ownership in Virginia which had been used by both parties for different purposes: timber harvesting by Greenleaf Johnson Lumber Company and military training exercises by the federal government under Garrison's authority as Secretary of War. The Supreme Court ruled in favor of Mr.Garrison stating that even though there were no formal records indicating governmental purchase or condemnation proceedings for this property, it had been utilized continuously and openly for public use without any objection from anyone including previous owners since 1821; thus establishing an implied dedication to public use doctrine which effectively granted ownership rights to the government based on its longstanding usage patterns rather than traditional legal documentation requirements.

The dissenting opinion in the case of Greenleaf Johnson Lumber Company v. Garrison, Secretary of War argued that the government's actions were not justified under its war powers and did not constitute a taking for public use. The justice believed that while the government has broad authority during times of war, this does not extend to seizing private property without compensation unless it is directly necessary for military operations or national defense. In this case, he felt there was no evidence presented to suggest such necessity existed. Furthermore, he contended that even if a seizure could be justified on these grounds, it would still need to serve some form of public use - which he also found lacking in this instance as the lumber taken from Greenleaf Johnson Lumber Company was used solely by one private corporation (the DuPont company) rather than being put towards any broader societal benefit or purpose.