In the 1913 case of Curriden v. Middleton, the United States Supreme Court dealt with a dispute over land ownership in North Carolina. The plaintiff, Curriden, claimed that he had purchased a tract of land from one J.R. Thigpen and his wife but later discovered that there was an existing mortgage on it held by defendant Middleton who subsequently foreclosed on the property when Thigpen defaulted on payments. Curriden sued to have his title confirmed and Middleton's claim dismissed arguing that he was an innocent purchaser for value without notice of the prior encumbrance (mortgage). However, evidence showed that at time of purchase, Curriden knew about this mortgage which invalidated his argument as an innocent buyer. The court ruled in favor of Middleton stating that since Curriden had knowledge about the pre-existing mortgage at time of purchase; hence he could not be considered as a bona fide purchaser for value without notice - someone who buys something without any reason to suspect issues like liens or other legal problems affecting their right to own it free and clear. Therefore, despite having bought and paid for the property himself after such knowledge meant accepting subject to whatever rights were held by others (Middleton) under previous agreements.

In the dissenting opinion for Curriden v. Middleton, it was argued that the court erred in its decision to dismiss the case on grounds of jurisdiction. The dissenting justices believed that there were sufficient grounds to establish federal jurisdiction over this matter and disagreed with the majority's interpretation of existing laws and precedents related to such cases. They contended that a more thorough examination of facts should have been conducted before making a determination about whether or not federal courts had authority in this instance. Furthermore, they expressed concern over potential implications of this ruling on future cases involving similar issues, arguing it could potentially limit access to justice for certain parties seeking redress through federal courts.