In the Northern Pacific Railway Company v. Adams case of 1903, the U.S Supreme Court ruled in favor of Adams. The dispute arose when Northern Pacific Railway Company claimed that it had a right to certain lands under an Act of Congress from 1864, which granted them land for every mile of track laid. However, before they could lay their tracks and claim the land, another Act was passed in 1870 withdrawing these privileges until a settlement with Indian tribes occupying those lands was reached. Despite this act being repealed later on by Congress in 1888 without any conditions attached to it; the court held that since at the time when railway company could have earned its grant (between passing and repeal), there were restrictions imposed by law i.e., settlement with Indians - hence they couldn't earn anything during this period as per original act's terms. Therefore, even after repeal they didn't automatically become entitled to all previously promised grants because those rights were already lost due to non-fulfillment within stipulated time frame.

In the dissenting opinion for Northern Pacific Railway Company v. Adams, Justice Harlan disagreed with the majority's interpretation of the land grant act in question. He argued that Congress intended to provide a substantial benefit to the railway company by granting it alternate sections of public lands along its route and did not intend to limit this benefit only to lands that were surveyed at the time of grant. According to him, any ambiguity in interpreting such grants should be resolved in favor of those who have received them from Congress rather than against them as done by majority decision. Furthermore, he contended that if there was an error made during surveying or classification process which resulted into inclusion or exclusion certain parcels from granted lands then it should be corrected later without affecting rights given under original grant instead of denying these rights altogether based on technicalities related with surveying procedures.