The Fritzlen v. Boatmen's Bank case in 1908 revolved around a dispute over the interpretation of a will and testament. The plaintiff, Mrs. Fritzlen, was the widow of Mr. Henry Fritzlen who had left his entire estate to her with an instruction that upon her death or remarriage, it should be divided equally among his siblings or their descendants per stirpes (by branch). After Mrs. Fritzlen's remarriage, she refused to distribute the estate as instructed by her late husband’s will arguing that Missouri law allowed widows absolute ownership of their husbands' estates regardless of any conditions set forth in their wills. However, Boatmen's Bank acting as trustee for Mr.Fritzlin’s relatives contested this claim leading to litigation which reached the Supreme Court after lower courts sided with Mrs.Fritzlin.The Supreme Court reversed these decisions ruling that while Missouri law did indeed grant widows full rights over their deceased husbands’ property,it could not override specific instructions provided within a validly executed will.Therefore,the court held that upon remarrying,Mrs.Fritzlin lost control over her late husband’s estate and it must be distributed according to his wishes expressed in his last testament.

In the dissenting opinion for Fritzlen v. Boatmen's Bank, Justice Harlan disagreed with the majority’s interpretation of Missouri law and its application to this case. He argued that under Missouri law, a married woman could not be held personally liable for her husband's debt unless she explicitly agreed to it in writing or through some other legally binding agreement. In this case, Mrs. Fritzlen had signed a promissory note as an accommodation endorser on behalf of her husband but there was no evidence that she intended to bind herself personally or understood the legal implications of what she was signing. Therefore, according to Justice Harlan, Mrs. Fritzlen should not have been held responsible for repaying her husband's debt because there was no clear proof that she had knowingly assumed personal liability.