In the United States v. Northern Pacific Railroad Company case of 1899, the U.S. Supreme Court ruled in favor of the government, asserting its right to reclaim public lands that had been granted conditionally to railroad companies for construction purposes but were not used as such. The Northern Pacific Railroad Company was given a large land grant by Congress in 1864 with conditions attached - it was required to build a railroad from Lake Superior to Puget Sound within a certain timeframe. However, when they failed to meet these conditions and instead sold some of this land for profit, the government sued them on grounds of breach of contract and misuse of public property. The court held that any part of this conditional land grant which remained unused by the company could be reclaimed by the government since it violated terms set out in their agreement.

In the dissenting opinion for United States v. Northern Pacific Railroad Company, it was argued that the majority's decision to void certain land grants made by Congress to the railroad company was incorrect. The dissenting justices believed that these grants were not fraudulent or illegal, but rather a legitimate exercise of Congressional power aimed at promoting development and settlement in the western territories. They contended that such decisions should be left up to Congress itself and not decided by courts based on their interpretation of what constitutes public interest. Furthermore, they pointed out inconsistencies in how similar cases had been handled previously, suggesting an unfair application of law against Northern Pacific Railroad Company specifically. Overall, they disagreed with both the legal reasoning and policy implications behind nullifying these land grants.