In the Northern Pacific Railway Company v. United States case of 1912, the Supreme Court ruled on a dispute over land grants given to railway companies during westward expansion in the late 19th century. The court held that lands granted by Congress to aid in construction of railroads were not subject to taxation by states until they had been sold or otherwise disposed of by the railroad company. The decision was based on an interpretation of federal law which stated that these lands were "free from taxation" as long as they remained unsold and part of a federally-granted right-of-way for transportation purposes. This ruling clarified how tax laws applied to such properties, providing significant financial relief for railway companies holding large tracts of unsold land.

The dissenting opinion in the case of Northern Pacific Railway Company v. United States, 1912, argued that the majority's decision to void land grants given to the railway company by Congress was incorrect. The dissenters believed that these grants were a contract between Congress and the railway company, which should be upheld as sacred under law. They contended that if any part of this agreement was illegal or unconstitutional, it should have been addressed at its inception rather than decades later after considerable reliance had been placed on it by both parties involved. Furthermore, they asserted that such retroactive invalidation could potentially destabilize other similar agreements and undermine confidence in governmental contracts overall. Therefore, they disagreed with the majority's ruling due to concerns about its potential implications for contractual stability and trustworthiness.