In the case of Broom v. Armstrong in 1890, the U.S. Supreme Court dealt with a dispute over land ownership in Texas between two parties: Broom and Armstrong. The land was originally granted by Mexico to one John McMullen before Texas became part of the United States, but due to various legal complications and transfers, its rightful owner came into question. The court had to determine whether or not an act passed by Congress on December 22nd, 1858 - which confirmed certain Mexican grants as valid - applied to this particular piece of property. Ultimately, it was decided that since McMullen's grant from Mexico did not meet all conditions set forth in said Act (specifically because he failed to establish residency), his claim (and therefore Broom's) could not be validated under it; thus ruling in favor of Armstrong.

In the dissenting opinion for Broom v. Armstrong, Justice Lamar argued that the majority's decision was inconsistent with previous rulings of the Court and violated principles of equity. He contended that a mortgagee should not be allowed to purchase property at his own sale without first obtaining permission from all parties involved or giving them an opportunity to redeem their interests in the property. In this case, he believed that Mr. Broom had been unfairly deprived of his right to redeem his interest in certain lands because Mr. Armstrong, who held a mortgage on those lands, purchased them at a foreclosure sale without notifying him or seeking his consent beforehand. According to Justice Lamar, such conduct amounted to fraud and should have been condemned by the Court rather than condoned.