The U.S. Supreme Court case Missouri Pacific Railway Company v. Fitzgerald in 1895 revolved around a dispute over land ownership rights between the railway company and John Fitzgerald, who claimed to have purchased the contested property from its original owners before it was granted to the railroad by an act of Congress. The court ruled in favor of Fitzgerald, stating that his purchase agreement had been made prior to any congressional grant given to the railway company for construction purposes. Therefore, he held rightful title over said lands under common law principles of "first in time, first in right." This decision underscored that federal grants do not supersede pre-existing private contracts or agreements regarding land ownership.

In the dissenting opinion for Missouri Pacific Railway Company v. Fitzgerald, Justice Brewer argued that the plaintiff should not be barred from seeking damages due to a technicality in filing procedures. He contended that it was unjust to deny compensation on such grounds when there was clear evidence of negligence by the railway company leading to injury or death of an employee. The majority's decision, he believed, prioritized procedural rules over substantive justice and fairness. Furthermore, he disagreed with their interpretation of federal law regarding employers' liability and asserted that Congress intended for injured workers or their families to have access to legal remedies regardless of state laws or court rulings limiting employer responsibility.