In Northern Pacific Railroad Company v. Ellis, the U.S. Supreme Court ruled in favor of the defendant, Mr. Ellis, who had been sued by the Northern Pacific Railroad Company for trespassing on land they claimed to own under a congressional grant from 1864. The court found that while Congress did indeed grant lands to railroad companies for construction purposes, it was not an absolute title but rather a "limited fee," meaning ownership came with certain conditions and restrictions related to railway use. In this case specifically, since no railway line had been constructed through the disputed property within ten years as required by law (the time limit set by Congress), full title never vested in the company and thus reverted back to public domain status before being purchased legally by Mr.Ellis.

In the dissenting opinion for Northern Pacific Railroad Company v. Ellis, Justice Lamar argued that the majority's decision was inconsistent with previous rulings of the court and violated principles of equity. He contended that a railroad company should not be allowed to sell land it had received from Congress under certain conditions before those conditions were met, particularly when such sales could harm innocent third parties who purchased the land in good faith. Furthermore, he believed that if a railroad company did sell such lands prematurely, it should at least be required to compensate purchasers for their losses upon reclamation by the government or other rightful owners. By failing to uphold these principles, Justice Lamar asserted that the court was effectively allowing corporations like Northern Pacific Railroad Company to profit from their own wrongdoing at others' expense.