In the Noble v. Union River Logging Railroad Company case of 1892, the U.S. Supreme Court ruled in favor of Union River Logging Railroad Company. The dispute arose over a land grant by Congress to aid in the construction of a railroad and telegraph line from Lake Superior to Puget Sound on the Pacific coast by Northern Pacific Railroad (NPR). NPR sold part of this granted land to Union River Logging Co., which was later contested by Secretary John W. Noble who claimed that these lands were not included within limits defined for such grants as they were reserved for Indian reservations at time when act was passed. However, court held that since reservation ceased before completion or acceptance of railroad's map showing definite location route, it fell within indemnity limits and thus could be lawfully sold to third parties like Union River Logging Co.

In the dissenting opinion for Noble v. Union River Logging Railroad Company, it was argued that the Secretary of Interior did not have the authority to approve or disapprove land grants after they had been made by Congress. The dissenting justices believed that once Congress had granted a tract of land to a railroad company, it became private property and could no longer be controlled by government officials. They contended that this interpretation was consistent with previous court decisions and federal laws regarding public lands. Furthermore, they expressed concern about potential abuses of power if executive branch officials were allowed to interfere in these matters post-facto. This view fundamentally disagreed with majority's stance which upheld Secretary’s decision as within his purview under existing law.