In the case of Santa Fe Pacific Railroad Company v. Lane, Secretary of the Interior in 1916, the Supreme Court ruled on a dispute over land rights between a railroad company and Native American tribes. The Santa Fe Pacific Railroad Company claimed that it had been granted certain lands by an act of Congress in 1866 for construction purposes. However, these lands were also part of reservations set aside for Native American tribes under treaties made before this act was passed. The court held that while Congress has power to abrogate treaty provisions, such intent must be clear and plain; if there is any doubt or ambiguity about Congressional intent to do so then courts should rule against it. In this case, since there was no explicit mention in the Act about overriding previous treaties with native tribes regarding their reservation lands, those rights remained intact despite claims by the railroad company.

The dissenting opinion in the case of Santa Fe Pacific Railroad Company v. Lane, Secretary of the Interior disagreed with the majority's interpretation of an 1866 Act granting lands to railroads for construction purposes. The dissent argued that this act did not grant a right-of-way to railroad companies but rather only allowed them to purchase land from private owners at a fair market price. They believed that the government retained control over these lands and could regulate their use as it saw fit, including denying access if necessary for public interest reasons such as conservation or preservation efforts. Furthermore, they contended that even if there was ambiguity in interpreting this law, any doubt should be resolved in favor of preserving public lands rather than transferring them into private hands without clear legislative intent.