In the Worthington v. Robbins case of 1890, the U.S Supreme Court ruled on a dispute involving land ownership and property rights. The appellant, Worthington, claimed that he had purchased certain lands from the United States government in Illinois under swamp-land laws but later discovered that these lands were part of a railroad grant to Illinois Central Railroad Company by Congress in 1850. He filed suit against Robbins who held title to these lands through conveyance from this company. The main issue was whether or not the swampland act could override previous grants made by Congress for other purposes such as railroads. The court upheld lower courts' decisions favoring Robbins and ruled against Worthington's claim stating that when there is conflict between two statutes - one granting land for railroads and another reserving it as swampland - priority should be given to specific over general legislation; thus affirming Congressional intent behind each statute. In this case, since railroad grant was more specific than swamp-land reservation law which applied generally across all states with such areas; former prevailed over latter.

In the dissenting opinion for Worthington v. Robbins, Justice Lamar argued that the majority's decision was inconsistent with previous rulings and principles of equity. He contended that a mortgagee should not be able to obtain a decree of sale without first proving their claim in court, as this would violate the rights of mortgagors who may have valid defenses or counterclaims. Furthermore, he disagreed with the majority's interpretation of Illinois law regarding redemption rights after foreclosure sales. According to him, such laws were designed to protect debtors from being deprived of their property without due process and fair compensation - objectives which could not be achieved if courts allowed mortgagees to bypass these protections by selling properties before confirming their claims. Thus, he believed that the lower court had erred in granting an absolute decree for sale instead of a conditional one pending proof of claim.