In the 1904 case of Gleason v. White, the U.S. Supreme Court dealt with a dispute over land ownership in Florida. The plaintiff, Gleason, claimed that he had purchased certain lands from the state of Florida which were subsequently sold by the state to another party (White). He sought to have this second sale declared void and his own title confirmed. However, it was found that at no point did Gleason hold legal title to these lands; instead he held an "equitable interest" based on a contract for purchase which was subject to conditions precedent before full ownership could be transferred - conditions which were not fulfilled prior to Florida's sale of land to White. Therefore, since Gleason never acquired legal title from Florida and failed in performance on his part under his contract with them so as they might convey such legal title upon him according thereto; hence there is nothing left for equity jurisdiction or relief in favor thereof against said subsequent purchaser (White) who bought same lands later directly from State without notice about any such previous agreement between it and Gleason.

In the dissenting opinion for Gleason v. White, it was argued that the court majority had erred in its interpretation of the law and application to this case. The dissenting justices believed that Mr. Gleason should not have been held liable for damages resulting from a fire on his property which spread to neighboring properties due to high winds, as he did not intentionally or negligently cause the fire but rather it started accidentally during normal operations of his business. They contended that under common law principles, a person is generally only responsible for harm caused by their intentional or negligent actions and there were no statutory provisions at play here overriding those principles. Furthermore, they disagreed with the majority's view that Mr. Gleason’s operation of a sawmill inherently carried an unusual risk of causing fires; instead they viewed such risks as ordinary hazards associated with many types of businesses and activities.