The case of Bratton v. Chandler revolved around a dispute over oil and gas leases in New Mexico. The plaintiffs, Bratton et al., claimed that the defendants, Chandler & Walden, had fraudulently obtained these leases from them under false pretenses and sought to have them canceled. They alleged that the defendants misrepresented their intentions by stating they would only use the land for grazing cattle when in fact they intended to drill for oil and gas all along. However, the Supreme Court ruled against Bratton et al., holding that there was no evidence of fraudulent misrepresentation on part of Chandler & Walden as it could not be proven beyond doubt that at time of obtaining lease they were aware about presence or potentiality of oil or gas on said lands.

In the dissenting opinion for Bratton et al. v. Chandler et al., Justice Holmes disagreed with the majority's decision to deny recovery of damages by a third party who was not directly involved in a contract but suffered losses due to its breach. He argued that if an individual knowingly enters into a contract which, when broken, would cause harm to another person or entity, they should be held liable for any resulting damage even if there is no direct contractual relationship between them and the injured party. This principle of liability should apply especially in cases where it can be reasonably foreseen that such harm may occur as a result of breaching the agreement. The justice believed this approach better reflected common law principles and provided more equitable outcomes than limiting liability strictly based on privity of contract.