In the case of Orr v. Gilman in 1901, the U.S Supreme Court ruled on a dispute involving railroad companies and their shareholders. The plaintiff, Orr, was a shareholder in two railroads that had been consolidated into one company by an act of Congress. He claimed that this consolidation violated his rights as a shareholder because he did not consent to it and argued for compensation from the defendant, Gilman who was another shareholder. However, the court held that since both companies were incorporated under federal law and their charters gave Congress power over them including alteration or amendment of these charters; therefore they could be legally consolidated without unanimous consent from all shareholders. Furthermore, no individual property right was infringed upon by this action according to Justice Peckham's majority opinion.

In the dissenting opinion for Orr v. Gilman, it was argued that the majority's decision to uphold a lower court ruling in favor of Gilman was incorrect. The dissenting justices believed that Orr had a valid claim against Gilman and should have been allowed to pursue his case further. They disagreed with the majority's interpretation of maritime law and felt that they were ignoring important precedents set by previous cases. Furthermore, they contended that this decision would unfairly limit individuals' ability to seek legal recourse in similar situations in the future.