The United States Supreme Court case of the United States v. St. Louis, San Francisco & Texas Railway Company in 1925 revolved around a dispute over land ownership rights between the U.S government and the railway company. The government claimed that certain lands within Indian Territory (now Oklahoma) were part of public domain and thus belonged to them, while the railway company argued they had acquired these lands through an act passed by Congress in 1870 granting them right-of-way for railroad construction purposes. The court ruled in favor of the railway company stating that when Congress granted this right-of-way, it implicitly transferred title to those specific parcels of land from public domain into private hands - namely, those of the railway company. Therefore, these lands could not be considered as part of public domain anymore.

In the dissenting opinion for United States v. St. Louis, San Francisco & Texas Railway Company, Justice McReynolds argued that the majority's decision was based on a misinterpretation of the law and an overreach of judicial power. He contended that Congress did not intend to give courts such broad authority in interpreting railroad rates under the Transportation Act of 1920. According to him, it was inappropriate for courts to intervene in rate-setting decisions unless there were clear violations or abuses by regulatory bodies like Interstate Commerce Commission (ICC). Furthermore, he believed that ICC had acted within its statutory powers when setting rates for railroads and thus should be upheld rather than overturned by court intervention. In his view, this case represented an unwarranted intrusion into administrative matters best left to expert agencies.