In Rakes v. United States (1908), the U.S. Supreme Court ruled on a case involving land rights and homesteading laws in relation to railroad companies. The plaintiff, John I. Rakes, had filed for a homestead claim on public lands in Washington state that were also claimed by the Northern Pacific Railroad under an 1864 Congressional land grant act which gave railroads ownership of odd-numbered sections within certain distances of their tracks as part of incentives to build transcontinental lines. Rakes argued that he was entitled to the property because his claim predated when the railroad surveyed its route through this area; however, it was after Congress had passed its law granting these lands to railroads but before they were officially designated or mapped out. The court sided with Northern Pacific Railroad stating that once Congress approved giving these lands over, all such properties became off-limits for new homesteading claims even if not yet identified or surveyed by any specific railway company at that time. Therefore, despite filing his claim first chronologically speaking against what would later become known as Northern Pacific's holdings thereon - Mr.Rake's application was deemed invalid due to federal legislation favoring corporate interests above individual settlers during this period.

In the dissenting opinion for Rakes v. United States, Justice Harlan argued that the majority's decision was a misinterpretation of the law and an overreach of federal authority. He believed that it was not within Congress' power to regulate or penalize personal behavior such as polygamy unless it directly affected interstate commerce or other federal interests. Furthermore, he contended that even if Congress did have this power, they had not clearly expressed their intent to criminalize polygamy in the legislation at issue in this case. Therefore, he disagreed with the majority's interpretation of ambiguous language in favor of broad federal powers and against individual liberties.