In the United States v. Winona and St. Peter Railroad Company case of 1896, the Supreme Court dealt with a dispute over land grants given to railroads by Congress in Minnesota. The court had to decide whether certain lands were part of an indemnity limit or place limit under these grants, which would determine if they could be claimed by the railroad company or not. The government argued that some lands within granted areas were reserved for Indian tribes and thus excluded from what could be claimed by the railroad company under its grant. However, after examining previous decisions and legislation related to this issue, as well as considering arguments about how such land grants should be interpreted generally, the court ruled in favor of Winona & St Peter Railroad Co., stating that once reservation for Indians ceased those lands fell within their grant limits.

The dissenting opinion in the case of United States v. Winona and St. Peter Railroad Company argued that the majority's decision was inconsistent with previous rulings on similar cases, specifically those involving land grants to railroad companies by Congress. The dissenters believed that these lands were not meant to be sold for profit but rather used for building railroads as intended by Congress when it made the grant. They contended that allowing such sales would undermine public policy objectives aimed at promoting transportation infrastructure development across the country. Furthermore, they disagreed with the majority's interpretation of Congressional intent behind these land grants and maintained that any ambiguity should have been resolved in favor of public interest rather than private gain.