In the case of United States v. Great Northern Railway Co., 1932, the U.S Supreme Court ruled in favor of the United States government. The dispute centered around whether or not a railroad company could claim mineral rights to land granted by Congress under an 1864 Act which provided for construction of railroads across public lands. The Great Northern Railway Company had claimed ownership and mining rights to oil deposits found beneath its right-of-way on these federally-granted lands in Montana. However, the court held that while railway companies were entitled to surface rights necessary for constructing and maintaining their railways, they did not have subsurface or mineral rights unless explicitly stated by Congress - which it was not in this case. Therefore, such resources remained property of the federal government.

The dissenting opinion in the case of United States v. Great Northern Railway Co., 1932, argued that the majority's decision to allow the government to recover damages from a railway company for forest fires caused by its negligence was incorrect. The dissenters believed that this ruling went against previous court decisions and legal principles regarding liability for property damage. They contended that under common law, one could only be held liable for damage caused by their own actions or those they had control over - not natural disasters like forest fires which are beyond human control once started. Furthermore, they pointed out inconsistencies in how much compensation was awarded based on speculative estimates of timber value rather than actual loss incurred due to fire destruction.