In the case of Martin, Successor to Lawler, Secretary of Highways of Pennsylvania v. Creasy et al., 1958, the U.S Supreme Court dealt with a dispute over land ownership and compensation in relation to eminent domain laws. The state had taken private property for public use without providing just compensation as required by the Fifth Amendment. The appellants were officials from Pennsylvania who appealed against an order that directed them to pay damages for taking possession of appellees' lands before paying any compensation. They argued that they were immune from such orders due to their official positions and because they believed no federal question was involved in this matter since it was purely based on state law issues regarding condemnation proceedings under eminent domain laws. However, the court ruled against them stating that even though they are state officials, they cannot violate constitutional rights (in this case - right to receive just compensation when private property is taken for public use) without facing legal consequences.

In the dissenting opinion for Martin, Successor to Lawler, Secretary of Highways of Pennsylvania v. Creasy et al., Justice Frankfurter disagreed with the majority's decision that a state could not take private property without just compensation even if it was for public use. He argued that this interpretation went against historical precedent and ignored the fact that states have traditionally had broad powers in determining what constitutes "public use." Furthermore, he contended that such decisions should be left up to local authorities who are more familiar with their community's needs rather than federal courts. He also expressed concern about potential negative impacts on future infrastructure projects due to increased litigation and costs associated with providing compensation for every piece of land taken by eminent domain.