In the Northern Pacific Railway Company v. De Lacey case of 1898, the U.S Supreme Court ruled in favor of Northern Pacific Railway Company. The dispute arose when De Lacey claimed ownership over a piece of land that was also claimed by the railway company under an Act passed by Congress granting lands to aid in building railroads and telegraph lines from Lake Superior to Puget Sound on the Pacific coast. The court held that even though there were irregularities in how some sections were numbered within townships along the railroad line, it did not invalidate or affect titles granted under this act for other sections correctly numbered within those same townships. Therefore, since De Lacey's claim fell into one such section with numbering errors, his claim was dismissed and title confirmed as belonging to Northern Pacific Railway Company.

In the dissenting opinion for Northern Pacific Railway Company v. De Lacey, Justice Harlan disagreed with the majority's interpretation of the land grant act and its application to this case. He argued that Congress intended to give alternate sections of public lands to aid in building a railroad, not all lands within those limits regardless of their character or value. The language used by Congress was clear in his view - it did not include mineral lands but only agricultural and timberlands. Therefore, he believed that the railway company had no right over valuable mineral deposits found on these granted lands unless they were specifically mentioned in the grant itself which was not done here. Furthermore, he pointed out that even if there were ambiguities regarding what kinds of land are included under 'public lands', any such doubts should be resolved in favor of government rather than private corporations like Northern Pacific Railway Company.