In the case of Washington Gas Light Company v. Lansden (1898), the U.S Supreme Court ruled in favor of the plaintiff, Washington Gas Light Company. The company had sued Lansden for non-payment of gas bills, arguing that they were entitled to charge him based on a special rate established by an act passed by Congress in 1848. This act allowed them to set their own rates and was not superseded by any subsequent legislation or regulation from local authorities. On his part, Lansden contended that he should be charged according to a lower rate set out in regulations introduced later by District Commissioners under authority granted them by Congress. The court held that while Congress did have power over public utilities within the District of Columbia and could delegate this power as it saw fit; there was no evidence suggesting it intended for these later regulations to override its earlier Act allowing companies like Washington Gas Light Company to determine their own rates.

In the dissenting opinion for Washington Gas Light Company v. Lansden, Justice Harlan disagreed with the majority's interpretation of the tax law in question. He argued that a literal reading of the statute would not lead to an absurd result as suggested by his colleagues but rather it was their interpretation which led to such a conclusion. According to him, if Congress had intended for gas companies' real estate holdings used in business operations to be exempt from taxation, they would have explicitly stated so within the legislation itself. Furthermore, he contended that there was no reason why these types of properties should be treated differently than other businesses' real estate assets when it came to taxation matters and thus saw no justification for creating such an exemption through judicial decision-making.