In the case of Western Pacific Railroad Company v. United States in 1924, the Supreme Court ruled on a dispute between the railroad company and the federal government over land rights. The Western Pacific Railroad Company claimed that it had been granted certain lands under an 1862 Act of Congress, but these claims were contested by other parties who argued they held prior rights to those lands based on earlier laws or treaties with Native American tribes. The court found in favor of the United States, ruling that while Congress did grant some land to railroads for construction purposes under various acts including one from 1862, this did not include all lands within specified boundaries regardless of previous ownership or entitlements. Therefore, any pre-existing legal claims to such properties would take precedence over later grants made by Congress.

In the dissenting opinion for Western Pacific Railroad Company v. United States, it was argued that the Interstate Commerce Commission (ICC) did not have authority to regulate rates on intrastate commerce unless there was a direct effect on interstate commerce. The dissenting justices believed that in this case, the ICC had overstepped its bounds by regulating rates of an entirely intrastate business operation under the guise of protecting interstate trade. They maintained that such regulation should be left to state authorities unless there is clear and substantial evidence showing detrimental effects on interstate commerce. Furthermore, they contended that federal intervention in purely local affairs could lead to unnecessary centralization of power and potential abuse thereof.