The U.S. Supreme Court case Galveston, Harrisburg and San Antonio Railway Company v. Wallace in 1911 revolved around a dispute over land ownership between the railway company and an individual named Wallace. The railway company claimed that it had purchased the disputed land from its original owner before he sold it to Wallace, but there was no record of this transaction at the county courthouse where such records were kept. The court ruled in favor of Wallace, stating that if a deed is not recorded properly according to state law, then subsequent purchasers have no legal obligation to honor it even if they are aware of its existence. This ruling upheld the importance of recording deeds correctly and reinforced property rights for individuals against corporations.

In the dissenting opinion for Galveston, Harrisburg and San Antonio Railway Company v. Wallace, Justice Oliver Wendell Holmes Jr. disagreed with the majority's decision to hold a railway company liable for damages caused by an employee who was not acting within his scope of employment at the time of incident. He argued that it is unjust to impose liability on employers when their employees act outside their job duties without explicit or implicit authorization from them. The justice contended that such a ruling would unfairly burden businesses and could potentially lead to abuse in litigation as plaintiffs might seek compensation from companies rather than individuals due to their deeper pockets.