The United States Supreme Court case, United States v. Chicago, Milwaukee and St. Paul Railway Company in 1904 revolved around a dispute over land grants given to the railway company by Congress for the construction of railroads across public lands. The government argued that certain sections of land were not included in these grants because they had been reserved for Indian tribes before the passage of the granting act. However, the railway company contended that it was entitled to these lands as they were part of an even-numbered section within twenty miles on each side of its railroad line - which according to legislation would be granted to them. The court ruled in favor of the U.S., stating that any reservation or withdrawal from sale or settlement made by competent authority prior to a grant is excluded from such grant unless expressly included therein. Therefore, since those particular sections had already been reserved for Indians when Congress passed its act granting lands to aid in building railroads through territories like Wisconsin and Minnesota; those specific parcels did not fall under what was intended for allocation towards railroad development.

In the dissenting opinion for United States v. Chicago, Milwaukee and St. Paul Railway Company, Justice Harlan argued that the majority's decision undermined Congress' constitutional authority to regulate interstate commerce. He contended that by allowing states to impose their own regulations on railroads - even those involved in interstate trade - the Court was essentially permitting a patchwork of potentially conflicting state laws to govern what should be a uniform national policy area. This could lead to inefficiencies and confusion within the industry, harming both businesses and consumers alike. Furthermore, he believed this ruling contradicted previous Supreme Court decisions which had upheld federal supremacy over interstate commerce regulation against similar challenges from states' rights advocates.