The Northern Pacific Railroad Company v. Poirier case in 1896 revolved around a dispute over land ownership between the railroad company and an individual named Poirier. The Supreme Court ruled in favor of Poirier, stating that he had validly acquired title to the disputed property under the Timber Culture Act before it was repealed by Congress. This act allowed individuals to claim up to 160 acres of public land if they agreed to plant and cultivate trees on at least one-fourth of this area within eight years from date of entry. Despite not having fully complied with these conditions, Poirier's rights were protected because he made substantial efforts towards compliance prior to repealment, which demonstrated good faith effort as required by law for such claims.

The dissenting opinion in the Northern Pacific Railroad Company v. Poirier case argued that the majority's decision was inconsistent with previous rulings and interpretations of the law, specifically regarding land grants to railroad companies. The dissent contended that these lands were not meant to be sold for profit but rather used for building railroads and supporting infrastructure. It also pointed out that if a company could sell such lands without restriction, it would essentially amount to an unrestricted gift from Congress - something which had never been intended by lawmakers. Furthermore, they disagreed with the majority's interpretation of "mineral lands," arguing instead that this term should include all valuable minerals found within a given tract of land, not just those explicitly named in legislation or contracts.