In the case of Glover v. Patten (1896), the U.S Supreme Court was tasked with determining whether a contract for land purchase in Texas, which had been paid off but not yet officially transferred to the purchaser due to ongoing litigation, could be considered an asset of the purchaser's estate upon his death. The court ruled that it could indeed be considered as such. This decision was based on principles of equity and common law that recognize beneficial ownership even if legal title has not yet been transferred. Therefore, despite no formal transfer having taken place before Mr. Glover’s demise, he held equitable title to this property at his death because he had completed payment under his contract with Mrs.Patten prior to dying.

The dissenting opinion in the Glover v. Patten case argued that the majority's decision was incorrect because it failed to consider the full implications of its ruling on property rights and contracts. The dissent believed that by allowing a contract for land purchase to be voided due to an error in describing the property, they were undermining established principles of contract law and creating uncertainty for future transactions. They contended that if a mistake is made in good faith, it should not automatically nullify a contract; instead, there should be room for rectification or compensation. Furthermore, they disagreed with the majority's interpretation of Mississippi state law regarding land descriptions and felt this misinterpretation led them to an erroneous conclusion.