In the Northern Pacific Railroad Company v. Freeman case of 1898, the U.S Supreme Court ruled in favor of Freeman. The dispute arose when Northern Pacific Railroad Company claimed that it had a right to certain lands under an Act of Congress from 1864, which granted them every alternate section of public land on each side of their railroad line. However, before this grant was made effective by earning through construction and acceptance by the President, these lands were sold to private parties including Freeman. The court held that until such time as the company earned its grant and received approval from the President for its location and map, any disposal made by government stood good against claims based on subsequent events like completion or acceptance after such disposal. Therefore, since Freeman's purchase preceded these events he retained his rights over those purchased lands despite later developments related to railroad grants.

The dissenting opinion in the case of Northern Pacific Railroad Company v. Freeman argued that the majority's decision was incorrect because it failed to consider the specific circumstances surrounding this particular land grant. The dissent emphasized that Congress had intended for these lands to be used by railroad companies as a means of generating revenue, and therefore they should not be subject to taxation by individual states. Furthermore, they pointed out that previous court decisions had upheld this interpretation of Congressional intent. They also disagreed with the majority's assertion that allowing railroads to avoid paying taxes on these lands would result in an unfair burden on other taxpayers, arguing instead that such tax exemptions were necessary incentives for companies undertaking large-scale infrastructure projects like building railroads across vast stretches of undeveloped territory.