In the case of Nielsen v. Steinfeld, 1911, a dispute arose over land ownership in Arizona. The plaintiff, Nielsen, claimed that she had inherited the property from her late husband who had purchased it from an individual named Steinfeld. However, there was no record of this transaction and instead evidence showed that the land was originally granted to another party by Congress under a railroad grant before being sold to Steinfeld's company. The Supreme Court ruled in favor of Steinfeld stating that when Congress grants lands for railroads or other public purposes with conditions attached and those conditions are fulfilled by parties acting on good faith belief they are entitled to do so; then such parties acquire valid title against all except United States until its decision is made known through proper judicial proceedings instituted directly for purpose of declaring such forfeiture.

In the dissenting opinion for Nielsen v. Steinfeld, it was argued that the majority's decision to uphold a lower court ruling against Mrs. Nielsen, who sought damages after her husband died in an accident while working on a railroad construction project overseen by Mr. Steinfeld, was incorrect and unjustified under Arizona law at that time. The dissenting justices believed that there were sufficient grounds for negligence on part of Mr. Steinfeld as he failed to provide safe working conditions which led to Mr. Nielsen’s death due to his fall into an unguarded excavation pit near where he worked - something they considered foreseeable and preventable with proper safety measures in place.