In the 1911 case of R.J. Darnell (Incorporated) v. Illinois Central Railroad Company, the U.S Supreme Court was tasked with deciding on a dispute over land ownership rights between R.J. Darnell Inc., and the Illinois Central Railroad Company. The railroad company claimed that it had obtained title to certain lands under an act of Congress in 1850 which granted public lands to states for railway construction purposes, while Darnell argued that they held rightful claim due to their purchase from private owners who had acquired it through state patents issued before the congressional grant took effect. The court ruled in favor of Illinois Central Railroad Company, stating that at the time when these state patents were issued, there was no authority vested in any officer or department of government to dispose off these lands as they were reserved by law for specific uses i.e., railway construction purposes under Congressional Act 1850; hence those sales made prior to this act were invalid and did not confer any right or title upon purchasers like Darnell Inc.

The dissenting opinion in the case of R.J. Darnell (Incorporated) v. Illinois Central Railroad Company argued that the majority's decision to uphold a lower court ruling against Darnell was incorrect, as it failed to consider key aspects of contract law and unjustly penalized Darnell for actions beyond its control. The dissent contended that the railroad company had not fulfilled its contractual obligations by failing to provide sufficient cars for loading coal, thereby causing significant losses for Darnell. It also disagreed with the majority's interpretation of "reasonable time" within which performance should occur under a contract, arguing that this should be determined based on individual circumstances rather than fixed standards or averages. Furthermore, it criticized the majority’s refusal to allow evidence regarding industry practices and conditions affecting car supply during trial proceedings, asserting this denied Darnell an opportunity to fully present its case.