In the case of Nadeau et al. v. Union Pacific Railroad Company, 1919, the plaintiffs were landowners in Wyoming who sued the Union Pacific Railroad for damages caused by a fire allegedly started by sparks from one of its locomotives. The Supreme Court ruled that under federal law, railroads could be held liable for damages caused by fires started as a result of their operations even if they had not been negligent or at fault. This decision was based on an interpretation of the Federal Safety Appliance Act and other related laws which aimed to promote safety in railroad operations and protect property owners from damage due to such activities.

In the dissenting opinion for Nadeau et al. v. Union Pacific Railroad Company, it was argued that the majority's decision failed to properly interpret and apply the law regarding land grants to railroads by Congress in 1862 and 1871. The dissent contended that these laws did not grant ownership of mineral rights under railroad tracks to the railroad companies, but rather only surface rights necessary for construction and operation of a railway. It was further asserted that any valuable minerals found beneath such lands should be considered public property unless explicitly granted otherwise by Congress - which they were not in this case. Therefore, according to this view, Union Pacific Railroad Company had no legal claim over oil discovered underneath its railway lines as ruled by lower courts priorly; thus reversing those decisions would constitute an erroneous interpretation of federal law.