In the 1906 case Armstrong, Receiver v. Ashley, the United States Supreme Court dealt with a dispute over land ownership in Mississippi. The plaintiff, Armstrong (a receiver for a bankrupt railroad company), claimed that his predecessor had purchased certain lands from Ashley's father and paid for them in full but never received a deed to those lands. He argued that he was entitled to possession of these lands because they were part of the assets of the insolvent railroad company. On the other hand, Ashley contended that her father had only agreed to sell some portions of these lands and not all as alleged by Armstrong. The court ruled in favor of Ashley based on evidence presented which showed inconsistencies between what was stated in written contracts versus oral agreements made between both parties at different times about which parcels were intended for sale or not. It held that where there is ambiguity or uncertainty regarding terms within an agreement due to conflicting statements made at various points during negotiations leading up to it being finalized; such discrepancies should be resolved against party who prepared document (in this case - Armstrong). Therefore, since he failed prove beyond reasonable doubt his claim over disputed properties; judgment went towards defendant - Ms.Ashley.

In the dissenting opinion for Armstrong v. Ashley, it was argued that the majority's decision to uphold a lower court ruling - which allowed a receiver of an insolvent company to recover funds from shareholders who had received dividends out of capital rather than profits - was incorrect. The dissenting justices believed this interpretation contradicted established principles governing corporations and their shareholders' rights. They contended that once dividends were declared and paid in good faith by directors, they should be considered as debts owed by the corporation to its stockholders; thus, they could not be reclaimed unless fraud or illegality was involved. Furthermore, they pointed out that there is often difficulty distinguishing between what constitutes 'capital' and 'profits', making such rulings problematic. Therefore, these justices disagreed with penalizing innocent parties (shareholders) who acted in good faith based on decisions made by corporate officers.