In the case of Bullis v. O'Beirne in 1904, the United States Supreme Court dealt with a dispute over land ownership. The plaintiff, Bullis, claimed that he had purchased a piece of property from an individual who was not legally capable of selling it due to mental incapacity at the time of sale. On appeal to the Supreme Court after losing his case in lower courts, Bullis argued that he should be allowed to keep possession because he bought and improved upon it without knowledge or reason to suspect any fraud or defect in his title. However, this argument was rejected by Justice Holmes who delivered the opinion for a unanimous court stating that ignorance does not excuse taking advantage from someone else's mistake especially when there is no evidence showing good faith on part of purchaser like making inquiries about seller's capacity before purchase transaction took place.

The dissenting opinion in the case of Bullis v. O'Beirne argued that the majority's decision was incorrect because it failed to consider important aspects of contract law. The dissent believed that a promise made without consideration is not legally binding, and therefore cannot be enforced by a court of law. In this case, they felt that there was no valid contract between Bullis and O'Beirne because there was no evidence of any benefit conferred upon or detriment suffered by either party as a result of their agreement. Furthermore, they disagreed with the majority's interpretation of "moral obligation" as sufficient grounds for enforcing an otherwise unenforceable promise under New York state law. They contended that such an interpretation would open up floodgates for litigation based on vague notions of morality rather than concrete legal principles.