In the Roberts v. Northern Pacific Railroad Company case of 1894, the U.S Supreme Court ruled in favor of Northern Pacific Railroad Company. The dispute arose when Roberts claimed that he had a right to a piece of land under an act passed by Congress in 1864 which granted lands to the railroad company for building rail lines from Lake Superior to Puget Sound. However, before completion of this project, another act was passed in 1870 withdrawing all unsold and unreserved lands from market disposal until further notice. In this context, Roberts argued that his claim on the land predates this withdrawal as it was made after completion but before official acceptance by government inspectors. The court disagreed with Robert's argument stating that according to law, rights could only be established once construction is officially accepted by government inspectors and not merely upon its completion or operation commencement. Therefore, since Robert's claim came prior to such official acceptance (which happened post-1870 Act), it did not hold valid against Northern Pacific Railroad Company’s title over these lands granted through congressional acts.

In the dissenting opinion for Roberts v. Northern Pacific Railroad Company, it was argued that the majority's decision to uphold a lower court ruling against Mr. Roberts was incorrect because it failed to consider important aspects of contract law and property rights. The dissenting justices believed that when Mr. Roberts purchased land from the railroad company, he did so with an understanding of certain conditions attached to its use which were not explicitly stated in his deed but were implied by previous agreements between the railroad company and other parties involved in earlier transactions related to this land. They contended that these conditions should have been considered as part of Mr.Roberts' contractual obligations despite their absence from his specific deed agreement with the railroad company; thus making him liable for any breach thereof such as using said lands contrary to those stipulations (e.g., mining). Furthermore, they disagreed with how broadly majority interpreted federal laws governing railroads’ sale of public lands granted them by Congress arguing instead for a narrower interpretation more consistent with historical precedent and legislative intent behind these statutes.