In the case of St. Louis, Iron Mountain & Southern Railway Co. v. Wynne in 1911, the U.S Supreme Court ruled on a dispute involving land ownership and railroad rights-of-way. The plaintiff, Wynne, claimed that he owned a piece of land through which the defendant's railway line passed without his permission or any legal right to do so. The defendant argued that it had acquired an easement for its tracks from previous owners before Wynne purchased the property and thus was not trespassing on his property as alleged by him. The court held in favor of the railway company stating that even though there were no formal deeds granting them an easement over this strip of land when they laid their tracks originally; their open, continuous use over many years established prescriptive rights equivalent to an easement under Arkansas law at that time (which required only seven years). Therefore, they did not infringe upon Mr.Wynne’s property rights.

In the dissenting opinion for the case of St. Louis, Iron Mountain & Southern Railway Co. v. Wynne, Justice Holmes disagreed with the majority's decision to award damages to Wynne based on negligence by the railway company. He argued that there was insufficient evidence presented in court to prove that any negligence occurred on part of the railway company and thus it should not be held liable for damages caused by an accident involving its train carriages and a horse-drawn carriage driven by Wynne's husband which resulted in his death. In addition, he pointed out inconsistencies in witness testimonies regarding whether or not warning signals were given before crossing tracks where collision happened; these discrepancies cast doubt over claims made against railway company about their failure to provide adequate warnings prior making crossings safe for other road users like Mr.Wynne who unfortunately lost his life due this tragic incident.