The U.S. Supreme Court case Illinois Central Railroad Company v. Illinois in 1895 revolved around the issue of public trust doctrine, specifically regarding land submerged under navigable waters. The state of Illinois had granted a large portion of the Chicago harbor to the Illinois Central Railroad in 1869 but revoked it in 1873, leading to a legal dispute between them. The railroad company argued that they had been given absolute title to this property and thus its retraction was unlawful; however, the court ruled against them stating that such lands are held by states as trustees for their people and cannot be completely relinquished without specific legislative approval or unless it ceases being useful for public purposes like navigation or fishing. This landmark decision established an important precedent about public ownership and control over common resources.

The dissenting opinion in the Illinois Central Railroad Company v. Illinois case argued that the state of Illinois had full authority to grant a large portion of its harbor in Chicago to the railroad company, and then later revoke this grant. The dissenters believed that there was no constitutional issue with this action because states have complete control over their own property unless it interferes with federal commerce powers. They also disagreed with the majority's view that public trust doctrine prevented such actions by a state, arguing instead that each state should be able to determine how best to use its own resources for public benefit without interference from judicial review or interpretation of common law principles like public trust doctrine.