In the case of Cook v. Cook in 1951, the United States Supreme Court addressed a dispute over property rights between a divorced couple. The husband had transferred his interest in their jointly owned home to his wife during their divorce proceedings without receiving any compensation for it. After the divorce was finalized, he sued her for half of its value, arguing that she had unjustly enriched herself at his expense. However, the court ruled against him on grounds that he voluntarily gave up his share and received what he considered adequate consideration at the time: freedom from marital obligations and potential financial liabilities related to joint ownership of property post-divorce. Therefore, there was no unjust enrichment as claimed by him.

The dissenting opinion in the case of Cook v. Cook argued that the majority's decision to uphold a divorce decree from another state, despite one party not being present or represented during proceedings, was incorrect. The dissenting justices believed this violated due process rights under the Fourteenth Amendment and set a dangerous precedent for future cases. They contended that while states have broad powers to regulate domestic relations within their borders, they should not be able to impose judgments on individuals who are neither residents nor physically present in their jurisdiction at any point during legal proceedings. This view held that such an imposition would infringe upon individual liberties protected by constitutional law and undermine public faith in judicial fairness and integrity.