In the United States v. Union Pacific Railroad Company case of 1912, the Supreme Court ruled on a dispute over land rights between the federal government and a railroad company. The Union Pacific Railroad Company had been granted large tracts of land by Congress in order to build railroads across the country. However, certain sections were found to contain valuable coal deposits which led to contention as these lands were not explicitly included in their grant from Congress. The court decided that since there was no specific mention or exclusion of mineral resources within these lands when they were initially given to Union Pacific, it could be inferred that all resources contained therein would belong to them as well. Therefore, even though this was not expressly stated in their agreement with Congress, ownership of any discovered coal reserves fell under property rights held by Union Pacific due its possession and control over said territories.

The dissenting opinion in the case of United States v. Union Pacific Railroad Company argued that the majority's decision to allow the government to reclaim land granted to railroad companies was incorrect. The dissenters believed that once a patent for land had been issued, it could not be revoked or cancelled by Congress unless there was evidence of fraud or mistake. They contended that this principle should apply regardless of whether the recipient is an individual or a corporation and irrespective of how much time has passed since its issuance. Furthermore, they pointed out inconsistencies in previous rulings on similar cases where patents were upheld despite later discoveries about their original issuance conditions being unfulfilled at those times.