In the Bailey v. Sanders case of 1912, the U.S Supreme Court was tasked with determining whether a contract for land purchase in Indian Territory (now Oklahoma) could be enforced despite not having been approved by the Secretary of Interior as required by law at that time. The plaintiff, Bailey, had purchased lots from Sanders and later discovered that they were part of an allotment to a Creek citizen which necessitated approval from the Secretary before any sale or transfer could occur. When he learned this fact after paying most of his installments, he stopped further payments and sued to recover what he had already paid on grounds that their agreement was void due to non-compliance with federal laws governing such transactions. However, both lower courts ruled against him prompting an appeal to the Supreme Court. The Supreme Court upheld these rulings stating that while it's true federal law required such contracts be approved by the Secretary before becoming effective; failure to do so did not render them entirely null and void but merely suspended their operation until necessary approval is obtained. Therefore since no evidence showed attempts were made or would have been futile if made towards obtaining said approval; there wasn't sufficient basis for declaring their contract absolutely void hence denying recovery.

In the dissenting opinion for Bailey v. Sanders, 1912, it was argued that the court erred in its decision to uphold a lower court's ruling which denied compensation to an employee who was injured while working on a machine he had not been trained to operate. The dissenting justices believed that this case should have been treated as one of negligence on part of the employer and thus, they were liable for damages. They contended that employers are obligated under common law duty to provide their employees with safe machinery and proper instructions regarding their operation. In failing these duties, they become responsible for any resulting injuries or accidents. Therefore, according to them, Mr.Bailey deserved compensation from his employer because he got hurt due to lack of training provided by his employer.