In the Citizens' Bank v. Parker case of 1903, the United States Supreme Court ruled on a dispute involving a bank and an individual over payment obligations related to promissory notes. The plaintiff, Citizens' Bank, sought to recover from Mr. Parker for his alleged failure to pay certain promissory notes that he had endorsed as surety for another party who defaulted on their payments. However, Mr. Parker contended that he was released from liability because the bank extended the time of payment without his consent after maturity of these notes - an action which under common law would discharge him as surety. The court held in favor of Citizens’ Bank stating that while it is true extending time can release a surety if done so without their consent; this principle does not apply when extension occurs after debt has matured or become due unless there's proof showing harm caused by such delay in collection efforts against principal debtor (which wasn't proven here). Thus, even though extension happened post-maturity and without defendant’s knowledge/consent – it did not absolve him off his obligation towards those debts.

In the dissenting opinion for Citizens' Bank v. Parker, it was argued that the majority's decision to uphold a lower court ruling in favor of Parker contradicted established principles of contract law. The dissenting justices believed that when Citizens' Bank agreed to accept partial payment from Parker as satisfaction for his debt, they were essentially entering into a new contract with him. This new agreement should have superseded their original loan agreement and absolved Parker of any further obligation to repay his debt once he fulfilled the terms set out by this subsequent arrangement. However, by allowing Citizens' Bank to sue Parker for the remaining balance on his initial loan after accepting partial repayment under different terms, they felt that the Court was unfairly permitting creditors to renege on their agreements with borrowers at will without facing any legal consequences.