In the case of Oregon Short Line and Utah Northern Railway Company v. Mullan, 1895, the U.S Supreme Court ruled in favor of the railway company. The dispute arose when a tax was imposed on railroad lands by Idaho state officials despite an existing federal law that exempted these lands from taxation until their final sale or disposal. The railway company argued this action violated its rights under both federal statute and contract with the government. The court agreed, stating that states cannot impose taxes on federally granted land while it remains unsold because such actions interfere with federal control over those properties. Therefore, any state laws allowing for such taxation were deemed unconstitutional as they contravened supremacy clause which gives precedence to federal law where state and federal laws conflict.

In the dissenting opinion for Oregon Short Line and Utah Northern Railway Company v. Mullan, Justice Brewer argued that the majority's decision was inconsistent with previous rulings on similar cases. He contended that a railroad company should not be held liable for damages caused by sparks from its locomotive if it had taken all reasonable precautions to prevent such an occurrence. According to him, liability should only arise when there is negligence or misconduct on part of the railway company. He also disagreed with the majority's interpretation of Idaho state law, asserting that it did not impose absolute liability on railroads for fire damage but rather required proof of negligence or fault.