The Episcopal City Mission v. Brown case in 1894 revolved around a dispute over the will of Miss Sarah H. Eastman, who left her estate to the Episcopal City Mission (ECM) for charitable purposes. The executor of her estate, Mr. Brown, argued that this bequest was invalid because it violated Massachusetts' rule against perpetuities - a legal principle that restricts how far into the future an individual can control their property after death through their will. However, ECM countered by asserting that charities were exempt from this rule and therefore entitled to receive Miss Eastman's bequest as per her wishes. The U.S Supreme Court ruled in favor of ECM stating that while generally speaking trusts might violate rules against perpetuity; when it comes to charitable trusts they are indeed exceptions due to their public benefit nature. Therefore, despite Mr.Brown's objections about potential violation of state law regarding perpetuity restrictions on private estates; since Miss Eastman’s bequest was intended for charity work via ECM which serves public good – such laws did not apply here making her last wish valid and enforceable.

The dissenting opinion in the Episcopal City Mission v. Brown case argued that the court majority had erred by not recognizing a clear distinction between public and private charities. The dissenting justices believed that this distinction was crucial to determine whether or not a trust could be established for an indefinite number of beneficiaries, as was the case with the Episcopal City Mission's charitable activities. They maintained that while it may be true that trusts for public charities can have an indefinite number of beneficiaries, this should not apply to private charities like religious organizations because they do not serve a broad enough section of society. Therefore, according to their interpretation, such trusts would violate rules against perpetuities and uncertainty of objects which are fundamental principles in property law.