In the United States v. Northern Pacific Railroad Company case of 1903, the U.S. Supreme Court ruled on a dispute over land grants given to railroad companies by Congress in order to encourage westward expansion and development during the late 19th century. The Northern Pacific Railroad Company had been granted large tracts of land along its proposed rail lines but was accused by the government of violating terms set out in their agreement, specifically regarding selling or leasing parts of this land for non-railroad purposes such as logging or farming. The court found that while some violations occurred, they were minor compared to overall compliance with congressional intent behind these grants: promoting settlement and economic growth across Western states. Therefore, it decided not to cancel all remaining unsold lands from grant but only those where clear violations happened - a significant victory for Northern Pacific which could continue benefiting from these valuable assets.

In the dissenting opinion for United States v. Northern Pacific Railroad Company, Justice Harlan argued that the majority's decision was a misinterpretation of Congress' intent when granting lands to railroad companies. He believed that Congress intended these grants as incentives for railroads to build lines through undeveloped territories, not as gifts of valuable resources. Therefore, he disagreed with the majority's ruling that allowed Northern Pacific Railroad Company to retain ownership over mineral-rich land even though it had sold off its surface rights. According to Justice Harlan, this interpretation undermined public policy by allowing corporations to profit excessively from public lands at the expense of individual settlers and miners who were actually developing those lands and contributing directly towards national growth and prosperity.