In the case of Waller et al., Trustees v. Texas & Pacific Railway Company, 1917, the Supreme Court dealt with a dispute over land ownership in Louisiana. The Wallers claimed that they were rightful owners of certain lands under a will while the railway company asserted its title based on an Act of Congress from 1871 granting it to them for construction purposes. The lower courts ruled in favor of the railway company and this decision was appealed to the Supreme Court. The court held that although there may have been some irregularities in how Texas & Pacific obtained their title, these did not invalidate their claim because they had fulfilled their obligations under federal law by constructing railroads as required by Congress's grant. Therefore, any subsequent private claims (like those made by Waller) could not supersede this federally granted right.

The dissenting opinion in the case of Waller et al., Trustees v. Texas & Pacific Railway Company argued that the majority's decision to uphold a lower court ruling, which allowed for the railway company to be exempt from paying taxes on certain lands granted by Congress, was incorrect. The dissenters believed that this exemption constituted an unfair advantage and violated principles of equal protection under law. They contended that all property within a state should be subject to taxation unless explicitly exempted by law or constitutionally prohibited, and no such exemptions were present in this case. Furthermore, they disagreed with the interpretation of Congressional intent behind land grants given to railroads during their construction period as implying tax immunity. Instead, they saw these grants as incentives for building infrastructure rather than permanent privileges against taxation.