In the case of The United States ex rel. The Attorney General of the United States v. Delaware and Hudson Company, 1908, the Supreme Court dealt with a dispute over land patents issued by Congress to railroad companies as part of an effort to encourage westward expansion in America during the mid-19th century. Specifically, this case involved whether or not coal deposits found beneath these lands could be considered "mineral lands," which were excluded from such grants under federal law at that time. The Delaware and Hudson Company had been mining coal on some of these granted lands for years when it was sued by the U.S government who argued that because they contained valuable coal deposits, they should have been classified as mineral lands and thus ineligible for inclusion in any land grant patent given to railroads. However, after considering both historical context and legislative intent behind relevant laws passed by Congress regarding such matters back then; including those specifically related to railroad land grants; along with various other factors like common understanding about what constituted 'minerals' during those times etc., Supreme Court ultimately ruled in favor of Delaware & Hudson Co., holding that these disputed parcels did not qualify as 'mineral lands' within meaning intended under applicable federal statutes.

In the dissenting opinion for The United States ex rel. The Attorney General of the United States v. Delaware and Hudson Company, Justice Harlan argued that Congress had not exceeded its constitutional authority in passing legislation to regulate railroad rates across state lines. He contended that railroads were instrumentalities of interstate commerce and thus fell under federal jurisdiction. Furthermore, he believed that if a railroad company accepted benefits from such legislation (such as protection against competition), it should also accept any burdens or regulations imposed by the same law without complaint about constitutionality issues after-the-fact. Harlan maintained this was especially true when those regulations were designed to protect public interests rather than private ones.