In the case of Minidoka & Southwestern Railroad Company v. United States (1914), the Supreme Court ruled in favor of the U.S. government, stating that it had not violated its contract with Minidoka & Southwestern Railroad Company by constructing a canal on land granted to the railroad company for building railway lines. The court held that under an 1898 Act, Congress had reserved rights to any part of these lands necessary for irrigation or other purposes related to reclamation projects before they were patented and sold off as per agreement with railroads. Therefore, when Bureau of Reclamation constructed a canal across some parts of this land without paying compensation to Minidoka & Southwestern Railroad Company, it was within its legal right as per terms set out in original grant legislation.

In the dissenting opinion for Minidoka & Southwestern Railroad Company v. United States, it was argued that the majority's decision failed to consider important aspects of the case. The dissenting justices believed that there were significant issues with how the Interstate Commerce Commission (ICC) had handled its investigation into whether or not certain railroad companies should be allowed to increase their rates. They felt that this lack of thoroughness on part of ICC led them to make a hasty and ill-informed decision which adversely affected these railroads' ability to operate profitably while also maintaining necessary services for public use. Furthermore, they disagreed with majority’s interpretation of “just and reasonable” standard in determining rate increases, arguing instead for a more nuanced approach considering individual circumstances rather than blanket rulings.