In the 1946 case of Angel v. Bullington, the United States Supreme Court ruled in favor of Bullington, who had been sued by Angel for breach of contract regarding a land sale agreement. The court held that specific performance could not be enforced on an invalid contract. In this case, there was no valid contract because the terms were not sufficiently definite and certain to allow enforcement; it lacked mutual assent or meeting of minds between parties about its essential terms such as price and description of property to be sold. Therefore, since there was no enforceable agreement between both parties due to these ambiguities, Angel's claim for damages based on alleged breach was dismissed.

In the dissenting opinion for Angel v. Bullington, Justice Frankfurter disagreed with the majority's interpretation of North Carolina law and its application to this case. He argued that under North Carolina law, a judgment in a prior action could not be used as an estoppel in subsequent litigation involving different parties unless it was shown that the issue had been fully litigated and determined in the first suit. In his view, there was no evidence to suggest that this requirement had been met here. Furthermore, he contended that even if such evidence existed, it would still be inappropriate to apply collateral estoppel because doing so would violate principles of due process by depriving individuals of their right to have their day in court on issues affecting them personally.