In the 1896 case of Spokane Falls and Northern Railway Company v. Ziegler, the U.S. Supreme Court dealt with a dispute over land rights in Washington state. The plaintiff, Ziegler, claimed that he had acquired title to certain lands through pre-emption rights under federal law before they were granted to the defendant railway company by an act of Congress for construction purposes. The lower court ruled in favor of Ziegler but on appeal, the Supreme Court reversed this decision. It held that at the time when Ziegler filed his claim for pre-emption right, these lands were not subject to such claims as they had already been reserved by Congress for railroad grants even though no specific grantee was named at that point in time. Therefore, when subsequently these lands were granted specifically to Spokane Falls and Northern Railway Company by another act of Congress it received clear title free from any prior conflicting claims including those made by Ziegler.

In the dissenting opinion for Spokane Falls and Northern Railway Company v. Ziegler, it was argued that the majority's decision to uphold a Washington state law allowing private property to be taken for public use without just compensation violated the Fourteenth Amendment of the U.S. Constitution. The dissent contended that this ruling effectively allowed states to disregard federal constitutional protections regarding private property rights, which they believed was not within their power or jurisdiction. They further asserted that such an interpretation could lead to potential abuses by state governments in seizing private properties under eminent domain laws without providing adequate compensation or due process as required by federal law and precedent.