In the 1900 case of Audubon v. Shufeldt, the United States Supreme Court was tasked with determining whether a contract for exclusive rights to publish and sell certain ornithological works violated antitrust laws. The National Audubon Society had entered into an agreement with Robert Wilson Shufeldt that granted him sole publishing and selling privileges for these works in exchange for royalties paid to the society. However, this arrangement was challenged on grounds that it constituted a monopoly and thus infringed upon federal antitrust legislation. Upon review, the Supreme Court ruled in favor of Audubon Society and Shufeldt, finding no violation of antitrust laws within their contractual relationship. The court reasoned that copyright law inherently grants exclusivity to authors or owners over their intellectual property; therefore such contracts do not create illegal monopolies but rather uphold legally protected rights.

In the dissenting opinion for the case of Audubon v. Shufeldt, it was argued that the majority's decision to uphold a contract between two parties, despite one party being unaware of certain facts at the time of agreement, set a dangerous precedent. The dissenting justices believed this ruling could potentially encourage deceitful behavior in business transactions and undermine fair dealing principles. They contended that if an individual enters into a contract without full knowledge or understanding due to another party withholding information or misrepresenting facts, then such contracts should be considered voidable at least by those who were deceived. This perspective emphasized on maintaining integrity and fairness in contractual agreements rather than strictly adhering to their literal terms regardless of circumstances surrounding their formation.