The U.S. Supreme Court case Vicksburg, Shreveport & Pacific Railway Company et al. v. Anderson-Tully Company in 1920 revolved around a dispute over land ownership and the rights to harvest timber on that land between a railway company and a lumber company in Mississippi. The railway company claimed it had acquired the disputed property through purchase from individuals who received title from the state of Mississippi under an Act of Congress granting lands for railroad construction purposes, while the lumber company asserted its own claim based on purchases made directly from private owners who held titles predating those granted by the state to aid railroads. The court ruled in favor of Anderson-Tully Company, stating that at no point did full title vest into either party due to non-compliance with conditions set forth by Congress when making grants for public improvements such as railways; thus, original private claims retained validity.

In the dissenting opinion for Vicksburg, Shreveport & Pacific Railway Company et al. v. Anderson-Tully Company, Justice Holmes disagreed with the majority's decision that a railway company could be held liable for damages to private property caused by sparks from its locomotives. He argued that such liability was not supported by common law principles and would place an undue burden on railroads, which were essential to commerce and economic development at the time. Furthermore, he contended that it was unreasonable to hold companies responsible for damage resulting from their operations unless they had acted negligently or unlawfully in some way - neither of which had been proven in this case. In his view, any change in this area of law should come from legislation rather than judicial interpretation.