In the case of Washington-Virginia Railway Company v. Real Estate Trust Company of Philadelphia, 1914, the Supreme Court dealt with a dispute over land ownership and rights. The Washington-Virginia Railway Company had been granted a right-of-way by Congress to construct railway tracks across certain lands in Virginia. However, these lands were owned by the Real Estate Trust Company of Philadelphia who objected to this intrusion on their property rights without compensation. The court ruled in favor of the trust company stating that while Congress could grant such permissions for public use projects like railways under eminent domain laws, it was still necessary for just compensation to be paid to private landowners whose properties are affected or taken over for such purposes as per Fifth Amendment protections against taking private property without due process and fair compensation.

In the dissenting opinion for Washington-Virginia Railway Company v. Real Estate Trust Company of Philadelphia, Justice Holmes disagreed with the majority's decision to uphold a lower court ruling that allowed a real estate company to foreclose on property owned by the railway company. He argued that this foreclosure was unjust because it did not take into account an earlier agreement between both parties which stipulated that any disputes would be resolved through arbitration rather than litigation. In his view, this contract should have been honored and enforced as it represented a valid and mutually agreed upon method for dispute resolution. Furthermore, he contended that allowing such foreclosures without considering prior contractual agreements could potentially undermine trust in business contracts and transactions more broadly.