In the case of Chappell v. Waterworth, 1894, the United States Supreme Court dealt with a dispute over land ownership in California. The plaintiff, Chappell claimed that he had purchased a piece of property from one Mr. Pioche who held legal title to it under Mexican law before California became part of the U.S., and thus his claim was valid under the Treaty of Guadalupe Hidalgo which ended the Mexican-American War and required respect for existing property rights. However, defendant Waterworth argued that Pioche's original grant was invalid because it exceeded Mexico's limit on land grants at that time (eleven square leagues) without special governmental approval which Pioche did not have. The court ruled in favor of Waterworth stating that while indeed there were exceptions to this rule where larger grants could be made by obtaining special permission from government authorities; no evidence existed showing such permission had been granted to Pioche or any prior owner. Therefore, his grant exceeding eleven square leagues was void ab initio (from inception), making all subsequent transfers including those to Chappell equally void.

The dissenting opinion in the case of Chappell v. Waterworth argued that the majority's decision to dismiss the bill was incorrect, as it failed to consider important aspects of equity jurisdiction. The dissent emphasized that there were allegations within the bill which, if proven true, would have entitled plaintiffs to relief under established principles of equity jurisprudence. It pointed out that a court should not refuse its aid merely because some other remedy might be available elsewhere or at another time; rather it should focus on whether an adequate and complete remedy can be given without its intervention. Furthermore, they contended that dismissing a suit based solely on speculation about possible future remedies is contrary to well-established legal principles and undermines confidence in judicial processes.