In the 1930 case Custer v. McCutcheon, the United States Supreme Court ruled on a dispute involving land rights and mineral extraction in Oklahoma. The plaintiff, Custer, had leased land from an Indian tribe for oil drilling purposes under federal supervision. However, after discovering that part of this leased area was owned by McCutcheon (a non-Indian), he sought to have his lease agreement modified or cancelled so as not to include this portion of land. The lower court initially sided with Custer but upon appeal, the Supreme Court reversed this decision stating that since both parties were aware of their respective interests at the time they entered into their agreements and because there was no fraud involved in obtaining these leases; therefore it would be unjust to modify or cancel them now based on subsequent events.

The dissenting opinion in the case of Custer v. McCutcheon argued that the majority's decision to uphold a lower court ruling, which found in favor of McCutcheon and against Custer, was incorrect. The dissent contended that there were significant errors made during the trial process that should have resulted in a reversal of the original verdict. Specifically, they believed that certain evidence presented by McCutcheon was improperly admitted and prejudiced the jury against Custer. They also took issue with instructions given to jurors regarding how they should interpret specific legal concepts related to this case; these instructions were deemed misleading and confusing by those who dissented from the majority opinion.