In the United States et al. v. Great Northern Railway Co., 1951, the U.S Supreme Court ruled in favor of the United States government against Great Northern Railway Company regarding mineral rights on land granted to railroads by Congress in 1864 and 1875. The court held that these grants did not include minerals beneath the surface of lands patented to a railroad company under federal statutes authorizing such patents for right-of-way purposes only. Therefore, it was determined that subsurface oil and gas deposits were reserved for public ownership rather than being owned by private entities like railway companies who had been given surface rights as part of their chartering legislation from Congress.

In the dissenting opinion for United States et al. v. Great Northern Railway Co., Justice Robert H. Jackson disagreed with the majority's interpretation of the 1875 Act, arguing that it was not intended to grant only an easement but a limited fee made on an implied condition of reverter. He contended that this interpretation had been consistently upheld in previous cases and should be maintained for legal stability and predictability reasons. Furthermore, he argued that Congress' intent when passing the law was to encourage railroad construction by granting land rights, which would have included mineral rights as well given their economic value at the time. Therefore, according to Justice Jackson's view, Great Northern Railway Co.'s claim over oil and gas deposits under its right-of-way should have been recognized as valid.