In the Northern Pacific Railroad Company v. Walker case of 1892, the U.S Supreme Court ruled in favor of Northern Pacific Railroad Company. The dispute arose when Walker claimed ownership over a piece of land that was also claimed by the railroad company under an act passed by Congress granting lands to aid in building railroads from Lake Superior and Puget Sound. The court found that although Walker had purchased his claim from a pre-emption settler (someone who settled on public land with intention to purchase it), this did not give him superior rights over those granted to the railroad company by Congress. It was held that as long as there were no legal settlers on such lands at the time they were granted to companies for constructing railroads, these grants are valid against subsequent purchasers or settlers.

The dissenting opinion in the Northern Pacific Railroad Company v. Walker case argued that the majority's decision was inconsistent with previous rulings and interpretations of land grant statutes. The dissent believed that Congress intended to provide railroads with every alternate section of public lands, not just those specifically designated as mineral or non-mineral at the time of granting. They contended that any subsequent discovery or development of minerals on these lands should not affect their original classification or ownership rights granted by Congress. This interpretation would ensure a fair distribution between railroad companies and settlers, promoting both transportation infrastructure and settlement expansion concurrently without causing disputes over land value changes due to mineral discoveries after grants were made.