In the 1916 case of West v. Edward Rutledge Timber Company et al., the United States Supreme Court dealt with a dispute over land ownership in Arkansas. The plaintiff, West, claimed that he had purchased certain lands from the state of Arkansas which were part of an indemnity selection made by the state under an act of Congress granting swamp and overflowed lands to states. However, these same lands had been previously granted by Congress to railroads as part of their right-of-way grants. The defendant timber company held title through purchase from one such railroad company. The court ruled in favor of Edward Rutledge Timber Company stating that when there is a conflict between two federal statutes - one granting land for railroads and another giving swamp or overflowed lands to states - priority should be given to the earlier statute unless it was repealed or modified by later legislation; this principle wasn't applied here. Therefore, since railroad grants preceded swamp-land grants chronologically, they took precedence legally too.

The dissenting opinion in the case of West v. Edward Rutledge Timber Company et al., 1916, argued that the majority's decision to uphold a lower court ruling allowing for the seizure and sale of timber on disputed land was incorrect. The dissent believed that this action violated due process rights as it did not provide adequate notice or opportunity for hearing before depriving an individual of their property. They also disagreed with the interpretation of state law by both courts, arguing that it should have been interpreted more narrowly to prevent such seizures without proper legal proceedings. Furthermore, they contended that even if there were grounds for seizure under state law, federal constitutional protections should supersede these provisions and protect against unjust deprivation of property without due process.