In the United States v. Dalles Military Road Co., 1890, the Supreme Court ruled on a dispute over land grants given to railroad companies by Congress in Oregon. The case centered around whether or not these lands could be taxed by local governments before patents were issued and if they were subject to forfeiture for non-payment of taxes. The court held that while legal title remained with the government until patent issuance, equitable title was passed onto grantees upon approval of their maps of definite location. Therefore, these lands could indeed be subjected to taxation as real property under state law from this point onwards. However, it also clarified that such properties couldn't be forfeited for tax delinquency since federal law protected them from any form of involuntary sale prior to patent issuance.

In the dissenting opinion for United States v. Dalles Military Road Co., Justice Field argued that the majority's decision was a departure from established principles of law and equity. He contended that when Congress granted lands to Oregon for constructing military roads, it created an irrevocable contract with the state. This grant, he believed, could not be rescinded or altered without violating constitutional protections against impairing contractual obligations. Furthermore, he disagreed with the majority's interpretation of Congressional intent in subsequent legislation related to these grants. In his view, this later legislation did not aim to revoke previous land grants but rather sought only to prevent future abuses by limiting additional ones. Thus, he concluded that Dalles Military Road Company had a valid claim on lands originally granted under earlier laws and should have been allowed compensation for their loss due to government action.