In the case of Spokane and Inland Empire Railroad Company v. Whitley in 1914, the U.S. Supreme Court ruled on a dispute over land ownership between a railroad company and an individual named Whitley. The court found that while the Northern Pacific Railway had been granted certain lands by Congress to build its railway, it did not have rights to all lands within those limits. Specifically, if there were pre-existing valid claims on any of these lands before they were granted to the railway (such as homestead or mining claims), then those would take precedence over the grant given by Congress to Northern Pacific Railway. Therefore, since Whitley's claim was filed prior to when these particular lands were included in what was granted for construction of railways under Congressional acts from 1862-1870, his claim took precedence over that of Spokane and Inland Empire Railroad Company which later acquired some assets from Northern Pacific Railway.

The dissenting opinion in the case of Spokane and Inland Empire Railroad Company v. Whitley argued that the majority's decision to uphold a state law requiring railroads to pay damages for livestock killed on their tracks was an overreach of judicial power. The dissent contended that this ruling interfered with interstate commerce by imposing undue burdens on railroad companies, which could potentially disrupt trade between states. They also expressed concern about the precedent set by allowing individual states to regulate industries involved in interstate commerce, arguing it would lead to inconsistent regulations across different jurisdictions and create confusion for businesses operating nationally. Furthermore, they disagreed with the majority's interpretation of negligence laws, asserting that railroads should not be held liable unless there was evidence they had acted carelessly or recklessly.