The Northern Pacific Railroad Company v. Holmes case in 1894 revolved around a dispute over land ownership. The Northern Pacific Railroad claimed that it owned certain lands under an act of Congress from 1864, which granted the company large tracts of land to support its construction efforts. However, Holmes argued that he had acquired valid title to some parts of this land before the railroad's grant took effect. He based his claim on a preemption right - a legal principle allowing settlers on public lands to purchase them before they are offered for sale publicly. The Supreme Court ruled in favor of Holmes, stating that his preemption rights were established when he settled and improved the property prior to any action by the railroad company or government surveyors marking out its grant boundaries. Therefore, these rights superseded those given later by Congress' act granting lands to the railway company.

In the dissenting opinion for Northern Pacific Railroad Company v. Holmes, 1894, it was argued that the majority's decision to uphold a lower court ruling in favor of Holmes was incorrect. The dissenting justices believed that the Northern Pacific Railroad Company had not violated any laws by refusing to provide service to Holmes' business at his requested location because they were under no legal obligation to do so. They contended that railroads are private entities and as such have discretion over their operations unless explicitly regulated by law or contractually obligated otherwise. Furthermore, they disagreed with the majority's interpretation of "public convenience and necessity" which formed part of their reasoning for siding with Holmes - arguing instead this should be determined on a case-by-case basis rather than being universally applied across all situations involving railroad companies providing services.