The U.S. Supreme Court case Oregon Railway and Navigation Company v. Oregonian Railway Company (Limited), 1891, revolved around a dispute over land rights between two railway companies in the state of Oregon. The plaintiff, the Oregon Railway and Navigation Company, claimed that it had acquired certain lands under an act of Congress from 1866 which granted railroad companies right-of-way through public lands for construction purposes. However, these claims were contested by the defendant company who argued they held prior rights to some parts of this land due to their own congressional grant from 1870. The court ruled in favor of the defendant - stating that while both grants were valid; priority was given to those who first completed their rail line across any disputed territory as per established legal principles at that time.

In the dissenting opinion for Oregon Railway and Navigation Company v. Oregonian Railway Company (Limited), Justice Brewer argued that the majority's decision was based on a misinterpretation of the law, particularly in relation to land grants. He contended that Congress had intended to grant lands only for specific purposes, such as building railroads or other public works projects, not simply as a general gift to corporations. Furthermore, he disagreed with the majority's view that once these lands were granted they could be freely sold or transferred by their recipients without any restrictions from Congress. Instead, he believed that these land grants should always remain subject to congressional oversight and control so as not to undermine their original purpose. In his view, allowing corporations unrestricted rights over these lands would lead to abuses and exploitation at the expense of public interest.