In the United States v. Cleveland, Cincinnati, Chicago & St. Louis Railway Company case of 1917, the Supreme Court ruled on a dispute regarding land ownership and usage rights between a railway company and the federal government. The railway company had been granted certain lands by Congress in 1850 to build tracks but was later found to be using some of these lands for coal mining operations without permission from or payment to the government. The court held that while Congress had indeed given these lands to aid in railroad construction, it did not intend for them also to be used as sources of mineral wealth without any compensation going back into public coffers. Therefore, it ordered that all profits derived from such unauthorized uses should go back into public treasury rather than being kept by private corporations who were merely custodians entrusted with public property.

In the dissenting opinion for United States v. Cleveland, Cincinnati, Chicago & St. Louis Railway Company (1917), Justice Oliver Wendell Holmes Jr., joined by Justice James Clark McReynolds, disagreed with the majority's interpretation of the Hepburn Act and its application to private car lines. The justices argued that Congress did not intend to regulate private cars as common carriers under this law because they are fundamentally different from public railroads in terms of their operations and services provided. They also contended that imposing such regulations would be impractical due to these differences and could potentially disrupt commerce rather than promote it as intended by the legislation. Furthermore, they believed that if Congress had wanted to include private car lines within its regulatory purview under this act, it would have explicitly stated so in clear language instead of leaving room for judicial interpretation or inference.