The U.S. Supreme Court case St. Paul, Minneapolis and Manitoba Railway Company v. Phelps in 1890 revolved around a dispute over land ownership between the railway company and an individual named Phelps. The railway company claimed that it had been granted certain lands by Congress under an act passed in 1864, while Phelps argued he owned the property through preemption rights established prior to the passage of this act. The court ruled in favor of Phelps, holding that his claim to the land was valid as he had settled on it before any grant was made to the railroad company by Congress; thus his right of possession superseded any subsequent grants or claims from other parties including corporations like railroads.

In the dissenting opinion for the case of St. Paul, Minneapolis and Manitoba Railway Company v. Phelps, Justice Lamar disagreed with the majority's interpretation of Minnesota state law regarding land grants to railroad companies. He argued that under Minnesota law, a grantee (in this case, the railway company) could not acquire title to property until it had fulfilled certain conditions precedent set out in its charter - specifically, completion of a specified amount of track within a given time frame. In his view, since these conditions were not met by the railway company at issue here before it attempted to sell some of its granted lands to third parties (including defendant Phelps), those sales should be deemed invalid and ownership should revert back to original owners or their heirs rather than being held by such purchasers who bought them in good faith but without proper legal basis.