In the case of Northern Pacific Railroad Company v. Urlin, 1894, the U.S. Supreme Court was tasked with determining whether a land grant made by Congress to the Northern Pacific Railroad Company included lands that were not yet surveyed at the time of granting but later found to be within indemnity limits. The court ruled in favor of Northern Pacific Railroad Company, stating that unsurveyed lands within these limits were indeed part of their granted territory as per Congressional intent and previous rulings on similar cases. This decision clarified how federal land grants should be interpreted when it comes to unsurveyed territories and confirmed that such areas could still fall under granted rights if they are located within specified boundaries.

The dissenting opinion in the case of Northern Pacific Railroad Company v. Urlin argued that the majority's decision was based on a misinterpretation of the law and an incorrect application of legal principles. The dissenting justices believed that the railroad company had not violated any laws by selling land to settlers at a higher price than it had originally paid for it, as this was standard business practice and not prohibited by any legislation or contract terms. They also disagreed with the majority's view that such sales constituted fraud, arguing instead that they were legitimate transactions between willing buyers and sellers. Furthermore, they contended that even if there had been wrongdoing on part of the railroad company, it should have been addressed through individual lawsuits brought by affected parties rather than through government intervention.