In the 1916 case of Oregon & California Railroad Company et al. v. United States, the Supreme Court ruled in favor of the U.S government, asserting its right to reclaim public lands that had been granted conditionally to railroad companies but were not used for their intended purpose. The court held that if a land grant's conditions are violated by a corporation, then it forfeits its claim on those lands and they revert back to federal ownership. This decision was significant as it clarified how conditional land grants should be interpreted and enforced under law - specifically those given out during westward expansion in order to encourage infrastructure development like railroads.

In the dissenting opinion for Oregon & California Railroad Company et al. v. United States, Justice Holmes disagreed with the majority's interpretation of the 1866 and 1870 Acts granting lands to railroads in Oregon and California. He argued that these acts did not impose any trust on the granted lands but merely imposed conditions subsequent upon their use and disposal by grantees. The justice believed that if Congress had intended to create a trust relationship, it would have explicitly done so within legislation rather than leaving such an important matter open-ended or ambiguous. Furthermore, he contended that even if there was a breach of condition by selling more land than permitted under law or at higher prices, this should be addressed through forfeiture proceedings initiated by government instead of imposing new obligations retrospectively onto railroad companies based on reinterpretation of old laws.