In the 1896 Supreme Court case Coughran v. Bigelo, the court ruled on a dispute involving land ownership and mineral rights in Colorado. The plaintiff, Coughran, claimed that he had purchased mining property from Bigelo only to discover later that it was worthless because it contained no valuable minerals. He sued for fraud and deceit, alleging that Bigelo had misrepresented the value of the property. However, according to evidence presented at trial, both parties were aware of an assay report indicating low mineral content before finalizing their transaction. The Supreme Court held in favor of defendant Bigelo stating there was no misrepresentation or concealment by him as both parties knew about the condition of mine through an assay report prior to purchase agreement. Therefore, since there wasn't any fraudulent behavior involved from defendant's side while selling his property with low mineral content; hence plaintiff's claim for being deceived into buying a worthless piece is invalid.

In the dissenting opinion for Coughran v. Bigelo, it was argued that the majority's decision to uphold a lower court ruling - which held that an agreement between two parties involving land in Arizona Territory was not enforceable due to lack of consideration - failed to properly interpret and apply contract law principles. The dissenting justice believed that there had been sufficient consideration on both sides: one party agreed to sell his property while the other promised payment upon completion of certain conditions. He also disagreed with the majority's view about what constituted "valuable" or "adequate" consideration, arguing instead for a broader interpretation where any act or forbearance by one party at another’s request could be deemed valuable enough as long as it involved some detriment or inconvenience suffered by the promisee, regardless of its monetary worth. Furthermore, he contended that even if no legal obligation existed initially between these parties when they made their agreement (as per common law), such an obligation should have arisen once they began performing their respective parts under this arrangement.