In the Brigham v. Coffin case of 1892, the U.S Supreme Court ruled on a dispute involving maritime insurance and salvage rights. The owners of a schooner named "Hattie E. Wheeler" had insured their vessel with two different companies before it was damaged in a storm off the coast of Massachusetts. After being repaired by salvagers, the ship's owners claimed compensation from both insurers for total loss under their policies but also sold the saved materials to recover some costs. The insurers argued that they should not have to pay out because there was no 'total loss' as defined by their policy terms since part of the ship had been successfully salvaged and sold for value. The court held that even though parts were recovered, this did not negate claims for total loss if those parts could not be used again in repairing or rebuilding an identical vessel - which was true in this instance due to significant damage sustained during recovery efforts themselves (i.e., breaking up). Therefore, despite partial salvage success and subsequent sale proceeds received by plaintiffs from such operations separately outside insurance contracts involved here specifically covering only complete losses without any deductions whatsoever related thereto; defendants still owed them full amounts promised therein originally upon occurrence thereof accordingly.

In the dissenting opinion for Brigham v. Coffin, Justice Brewer argued that the majority's decision to uphold a conviction based on an ambiguous statute was unjust. He contended that ambiguity in criminal statutes should be resolved in favor of defendants, not against them. The law under which the defendant was convicted made it illegal to use any device or scheme with intent to defraud and obtain money through false pretenses from any person or corporation within Massachusetts. However, Brewer pointed out that this law did not clearly define what constituted a "device" or "scheme," nor did it specify whether these terms referred only to fraudulent actions taken within Massachusetts itself or also included those carried out elsewhere but affecting individuals within the state. Because of these ambiguities, he believed there were reasonable doubts about whether the defendant's actions actually violated this law as written and interpreted by courts at that time.