I should further explain.
In my research I cite about forty cases. Some cite Hatch vs Black and expand on the explanation.
There is extensive case law on this subject.
There is another law that applies it some of these situations. It is also an old federal law called the Unlawful Enclosures Act.
It was passed prior to homesteading and so its provisions are incorporated, by reference, into all homestead grants.
These laws do not infringe on private property rights because they are all incorporated in the land grant by reference. (Existing laws are all incorporated by reference even if it is not explicitly stated on the grant.)
I'm not sure how this applies to a homestead that historically never had a road across it.