In the United States v. Union Pacific Railway Company case in 1897, the Supreme Court ruled on a dispute over land rights between the federal government and a railroad company. The Union Pacific Railway Company had been granted certain lands by Congress to aid in building its transcontinental railway line. However, some of these lands contained valuable coal deposits that were not discovered until after construction was completed. The U.S government argued that it retained ownership of these mineral resources despite granting surface rights to the railway company under an 1862 Act of Congress which did not explicitly mention minerals or mining rights. The court held for Union Pacific, stating that when Congress made grants "in aid of works of internal improvement," such as railroads, they intended to convey all property interests unless there was explicit language reserving certain aspects (like mineral rights) for public use or benefit. Therefore, even though coal wasn't specifically mentioned in their grant from Congress, because it didn't exclude any subsurface materials either - this meant everything went with what they got above ground too.

The dissenting opinion in the United States v. Union Pacific Railway Company case argued that the majority's interpretation of the law was incorrect and overly broad. The dissenters believed that Congress did not intend to grant such extensive rights to railroad companies when it passed legislation related to land grants for railroads. They contended that these laws were designed primarily to facilitate transportation, not enable large-scale real estate speculation by railway corporations. Furthermore, they disagreed with the majority's view on how much discretion courts should have in interpreting statutes, arguing for a more restrained approach based on legislative intent rather than judicial interpretation.