In the case of St. Paul, Minneapolis and Manitoba Railway Company v. Todd County in 1891, the U.S Supreme Court ruled that a county could not tax railroad property situated on land granted to it by Congress under an act providing for the construction of railroads in Minnesota. The railway company had been given large tracts of public lands as part of a federal program to encourage railroad development across America's frontier regions. However, Todd County attempted to levy taxes against these properties which led to this dispute reaching the Supreme Court level. The court held that such taxation was prohibited because it would interfere with federal policy promoting transportation infrastructure expansion through land grants; thus infringing upon national sovereignty over public domain lands until they were sold or otherwise disposed off by Congress' direction. This decision reinforced principles regarding state versus federal jurisdiction over public lands and highlighted how local governments must respect Congressional intent when implementing their own policies.

In the dissenting opinion for St. Paul, Minneapolis and Manitoba Railway Company v. Todd County, Justice Lamar disagreed with the majority's ruling that a county in Minnesota could not tax railroad lands granted by Congress to the state before they were sold or used. He argued that such an interpretation of federal law was incorrect because it would mean that these lands are exempt from taxation indefinitely until they are sold or used by the railway company, which he believed was contrary to public policy and common sense. Furthermore, he contended that this decision violated principles of equal protection under law as it unfairly burdened other property owners who had to pay higher taxes while these valuable lands remained untaxed.