The U.S. Supreme Court case Washington and Idaho Railroad Company v. Coeur D'Alene Railway and Navigation Company in 1895 revolved around a dispute over land rights for the construction of railroad lines in Idaho. The Washington and Idaho Railroad Company (W&I) had obtained permission from Congress to build a railway line through certain public lands, but before they could begin construction, the Coeur D'Alene Railway and Navigation Company (CDA) claimed that it already owned these lands under state law. W&I sued CDA on this basis, arguing that federal law should take precedence over state law in this matter. The Supreme Court ruled in favor of W&I, stating that when there is conflict between federal legislation granting right-of-way through public lands for railway purposes with prior unperfected claims under local laws or regulations, the former prevails as per constitutional mandate which gives supremacy to federal laws over conflicting state provisions.

In the dissenting opinion for Washington and Idaho Railroad Company v. Coeur D'Alene Railway and Navigation Company, Justice Brewer argued that the majority's decision was flawed because it failed to take into account the nature of railroad construction at that time. He pointed out that railroads were not built in a continuous process but rather in sections, with each section being completed before moving on to the next one. Therefore, he believed it was incorrect for the majority to rule against Washington and Idaho Railroad based on their failure to complete their entire line within a specified timeframe when they had indeed finished significant portions of it. Furthermore, Justice Brewer disagreed with how much weight was given by his colleagues to minor technicalities regarding land rights instead of focusing more broadly on whether or not substantial progress had been made towards completing this important infrastructure project.