In the Northern Pacific Railroad Company v. Charless case of 1895, the U.S Supreme Court ruled in favor of Northern Pacific Railroad Company. The dispute arose when Charless claimed that he had a superior title to certain lands in Washington state which were also claimed by the railroad company under an Act of Congress from 1864 granting land rights for railway construction. The court held that even though there was ambiguity regarding whether these specific lands fell within granted or indemnity limits (areas designated as compensation if suitable sections are unavailable), it did not affect the validity of patents issued by government officers acting under authority from Congress. Therefore, any such ambiguities should be resolved in favor of grantees like Northern Pacific Railroad Company rather than individual claimants like Charless.

In the dissenting opinion for Northern Pacific Railroad Company v. Charless, Justice Brewer argued that the majority's decision to deny Northern Pacific Railroad Company's claim was incorrect. He believed that when Congress granted land to the railroad company, it intended for all of its lands within a certain boundary to be included in this grant, regardless of whether they were surveyed or unsurveyed at the time. According to him, this interpretation is supported by both legislative history and previous court decisions related to similar grants made by Congress. Therefore, he disagreed with the majority's view that only those lands which had been officially surveyed at the time of granting could be claimed by Northern Pacific Railroad Company under their charter from Congress.