The United States Supreme Court case of United States v. Southern Pacific Railroad Company in 1901 revolved around a dispute over land grants given to the railroad company by Congress. The government claimed that certain lands were not included in these grants, and thus still belonged to them, while the railroad company argued otherwise. The court ruled in favor of the Southern Pacific Railroad Company, stating that it was clear from both Congressional records and previous legal decisions that these lands had indeed been granted to the company. This decision affirmed private property rights against governmental claims and clarified ambiguities regarding federal land grants made for railway construction during this era.

In the dissenting opinion for United States v. Southern Pacific Railroad Company, Justice Harlan argued that the majority's interpretation of the Act of 1866 was incorrect and overly narrow. He believed that Congress intended to grant all lands within a certain distance from the railroad line to Southern Pacific, regardless of whether they were odd or even numbered sections. The majority's decision not to award alternate sections of land in California to Southern Pacific because they had been reserved by an earlier act for another purpose was seen as contrary to this intention. Furthermore, he disagreed with their assertion that these reservations could be implied from silence in legislation rather than explicitly stated. In his view, if Congress wanted such exceptions it would have clearly specified them in law.