The United States Supreme Court case of the United States v. Northern Pacific Railroad Company in 1893 revolved around a dispute over land grants given to the railroad company by Congress. The government argued that certain lands, which were part of an Indian reservation at the time but later opened for settlement, should not have been included in these grants. The court ruled in favor of the U.S., stating that when Congress made these land grants to aid railway construction, it did not intend to include lands reserved for Indians until they were officially opened up for settlement or sale by a treaty or other congressional action. Therefore, those sections within such reservations passed from public domain and ceased being "public lands" subject to disposal under general laws including railroad grant acts.

The dissenting opinion in the case of United States v. Northern Pacific Railroad Company argued that the majority's decision to void certain land grants made by Congress to the railroad company was incorrect. The dissenters believed that these land grants were a valid contract between Congress and the railroad, and thus should be upheld as such. They further contended that it was not within the Court's jurisdiction to interfere with or invalidate these contracts, especially given their importance for encouraging westward expansion and development at this time in U.S history. Additionally, they asserted that any ambiguities present in these contracts should have been resolved in favor of upholding them rather than nullifying them outright.