In the case of Washington Securities Co. v. United States (1913), the Supreme Court ruled on a dispute involving land patents and their associated rights. The Washington Securities Company had purchased lands from railroad companies, which were originally granted to them by Congress under an 1864 act for constructing rail lines in Oregon and California. However, these lands contained valuable timber resources that were later claimed by the U.S government under another law passed in 1891 aimed at preserving forests on public lands. The court held that when Congress issued land grants to railroads, it did not intend to include forest reserves within those grants unless explicitly stated otherwise; hence such reservations could be made after granting without violating any vested rights of grantees or purchasers from them like Washington Securities Company. Therefore, even though the company bought these properties before they became part of a forest reserve in 1906-07, it was subject to restrictions imposed thereafter because its title came with implied conditions allowing future governmental regulations for public interests like conservation.

In the dissenting opinion for Washington Securities Co. v. United States, Justice Holmes disagreed with the majority's interpretation of the law and its application to this case. He argued that a literal reading of the statute would not lead to an absurd result as suggested by his colleagues in their ruling. Instead, he believed that Congress intended for all corporations engaged in interstate commerce to be taxed on their entire net income, regardless if some part of it was derived from state or local operations or investments unrelated to interstate commerce activities. Moreover, he contended that there is no constitutional impediment preventing such taxation since it does not interfere with states' rights nor violate due process principles under Fifth Amendment protections because corporations are still free to conduct business within individual states without being subjected directly by federal tax laws imposed on interstate commercial transactions.