In the 1903 case of Wynn-Johnson v. Shoup, the United States Supreme Court dealt with a dispute over land ownership in Idaho. The plaintiff, Wynn-Johnson, claimed that he had purchased the property from its original owner and therefore held rightful title to it. However, defendant Shoup argued that he was entitled to possession of the property because it was part of a larger tract granted by Congress to aid in construction for Union Pacific Railroad Company's branch line (Oregon Short Line). The lower court ruled in favor of Shoup based on this congressional grant. The Supreme Court affirmed this decision after examining whether or not Johnson’s purchase occurred before or after Congress’ approval for railroad construction grants. They found no evidence suggesting Johnson bought his parcel prior to Congressional action; thus they concluded that at time of sale, original owner did not have valid title due to federal preemption through railway legislation. This case highlights how federal laws can override individual transactions if they conflict with national interests such as infrastructure development.

The dissenting opinion in the case of Wynn-Johnson v. Shoup argued that the majority's decision was inconsistent with previous rulings and interpretations of the law. The dissenters believed that a state has no right to tax an individual for property located outside its jurisdiction, regardless if it is tangible or intangible property. They maintained that this principle should apply even when such property is owned by a resident who derives income from it while residing within the state's borders. Furthermore, they contended that taxing out-of-state properties would lead to double taxation as these properties could also be taxed in their home states, which contradicts principles of fairness and equity inherent in taxation laws. Therefore, they disagreed with the majority’s ruling allowing Tennessee to impose taxes on bonds held by one of its residents but issued by other states or foreign governments.