Brown v. Guarantee Trust and Safe Deposit Company was a case heard by the Supreme Court of the United States in 1922. The case involved a dispute between the Guarantee Trust and Safe Deposit Company and the Brown family over the ownership of a safe deposit box. The Browns had rented the box from the company and had placed a large sum of money in it. When the Browns attempted to retrieve the money, the company refused to give it to them, claiming that the box had been rented to another party. The Browns sued the company, arguing that the company had breached its contract with them by not returning the money. The Supreme Court ruled in favor of the Browns, finding that the company had breached its contract with the Browns and was liable for damages. The Court held that the company had a duty to return the money to the Browns, and that the company had failed to do so. The Court also held that the company had acted in bad faith by not returning the money, and that the Browns were entitled to damages for the breach of contract. The Court also held that the company was liable for the costs of the lawsuit, including attorney's fees.

In the dissenting opinion of Brown v. Guarantee Trust and Safe Deposit Company, Justice Holmes argued that the majority’s decision was wrong because it failed to recognize a fundamental principle of contract law: that parties are bound by their agreement as written. He noted that while there may be some ambiguity in the language used in this particular case, it is not enough to override what he saw as clear contractual obligations between both parties. Furthermore, he argued that if courts were allowed to interpret contracts based on their own subjective understanding of what they believe should have been agreed upon then all contracts would become unenforceable due to uncertainty over how they will be interpreted by judges or juries. Ultimately, Justice Holmes concluded his dissent with an argument for judicial restraint when interpreting contracts and urged caution against allowing courts too much discretion when deciding cases such as these.