The U.S. Supreme Court case Kansas City, Fort Scott and Memphis Railroad Company v. Daughtry in 1890 revolved around a dispute over land ownership rights between the railroad company and Mr. Daughtry, who had purchased a tract of land from the United States government that was also claimed by the railroad under an act granting lands to Arkansas for railroads' construction purposes. The court ruled in favor of Mr. Daughtry, stating that at the time he bought his parcel of land from the government, it was not part of any granted or reserved lands for railway construction as per federal law; hence it could be sold to private individuals like him without infringing on any existing grants or reservations made by Congress for public uses such as railways development projects.

In the dissenting opinion for Kansas City, Fort Scott and Memphis Railroad Company v. Daughtry, Justice Lamar disagreed with the majority's ruling that a railroad company could be held liable for damages to livestock caused by sparks from its locomotive engines. He argued that such incidents were an inevitable part of operating a train and should not be considered negligence on the part of the railroad company. Furthermore, he contended that it was unreasonable to expect companies to adopt expensive technologies or methods in order to prevent these types of accidents. Instead, he believed it was incumbent upon farmers and other individuals who chose to live near railroads to take precautions against potential harm from passing trains.