In the case of Spokane & Inland Empire Railroad Company v. Campbell in 1915, the U.S Supreme Court ruled on a dispute involving land rights and railroad construction. The plaintiff, Campbell, owned land that was bisected by tracks laid down by the defendant, Spokane & Inland Empire Railroad Company. The company had obtained permission to lay these tracks from a previous owner of the property but did not have an official easement or right-of-way agreement with Campbell when he purchased it later on. When Campbell attempted to build across his own property where the tracks were located without obtaining approval from Spokane & Inland Empire Railroad Company first, they sued him for trespassing and won at trial court level. The Supreme Court reversed this decision upon appeal stating that since there was no formal easement agreement between both parties involved in this case; therefore, as long as Mr.Campbell's actions didn't interfere with train operations or safety measures taken by railway company then he could use his own property freely even if it meant crossing over existing rail lines.

In the dissenting opinion for Spokane & Inland Empire Railroad Company v. Campbell, Justice Holmes disagreed with the majority's ruling that a state law requiring railroads to maintain fences along their tracks was unconstitutional. He argued that such laws were within a state's police powers and did not violate due process rights under the 14th Amendment as claimed by the railroad company. Holmes contended that states have always had authority to regulate businesses in ways they deem necessary for public safety, even if those regulations might cause some inconvenience or financial loss to businesses. He also pointed out that similar fencing laws existed in many other states and had been upheld by courts without question of constitutionality. Therefore, he believed it was inappropriate for this Court to strike down Washington’s law on constitutional grounds when its purpose clearly was protecting people from harm caused by unfenced railways.