In the 1913 case of Archer v. Greenville Sand and Gravel Company, the U.S. Supreme Court was asked to determine whether a contract for land sale was enforceable when it included an agreement that the purchaser would not compete with the seller's business within a certain geographical area. The court held that such agreements were indeed enforceable if they were reasonable in scope and did not unduly restrict trade or competition. The plaintiff, Mr. Archer, had sold his sand and gravel business to Greenville Sand & Gravel Co., along with its accompanying land assets but later started another similar operation nearby which led to this dispute. This decision is significant as it set precedent on how courts view non-compete clauses in contracts - specifically those related to sales of businesses - by establishing that these provisions are valid provided they do not excessively limit commerce or unfairly disadvantage one party over another.

In the dissenting opinion for Archer v. Greenville Sand and Gravel Company, it was argued that the majority's decision failed to properly consider the rights of property owners in relation to navigable waters. The dissenting justices believed that while public interest is important, private property rights should not be completely disregarded or sacrificed. They contended that a more balanced approach was needed where both public and private interests are taken into account when determining whether a body of water is navigable or not. Furthermore, they disagreed with the majority's interpretation of "navigability", arguing it was too broad and could potentially lead to unjust outcomes for landowners who have bodies of water on their properties.