In the case of The St. Paul, Minneapolis & Manitoba Railway Company v. Wenzel in 1890, the U.S Supreme Court ruled on a dispute over land ownership between a railway company and an individual named Wenzel. The railway company claimed that it had been granted certain lands by Congress under an act passed in 1864 to aid in building a railroad from Lake Superior to Puget Sound. However, before this grant was made official through patenting (the legal process for transferring public lands into private ownership), Wenzel had already settled on part of this land and applied for preemption rights (rights given to settlers allowing them first chance at purchasing public land). When the conflict arose, both parties took their claims to court. The Supreme Court ultimately sided with Wenzel, ruling that his settlement and application for preemption rights preceded any claim by the railway company because they were established before the date when these lands were officially withdrawn from market sale due to being granted to the railroad via patenting procedures. Therefore, according to existing laws regarding federal land grants and settler's rights at that time period - which prioritized early settlers' claims over later ones - Wenzel's claim held precedence.

In the dissenting opinion for The St. Paul, Minneapolis & Manitoba Railway Company v. Wenzel case, it was argued that the court majority had erred in its interpretation of the law and application to this particular case. The dissenting justices believed that there was no legal basis for holding a railway company liable for damages caused by sparks from one of their locomotives if they have taken all reasonable precautions to prevent such an occurrence. They contended that accidents can still happen even with every precaution taken and thus should not automatically result in liability on part of the railway company. Furthermore, they disagreed with how evidence was evaluated during trial proceedings; specifically regarding whether or not negligence could be inferred solely based on damage occurring without further proof being required.