In the 1935 case Graham v. White-Phillips Co., Inc., the United States Supreme Court ruled on a dispute involving oil and gas leases in Oklahoma. The plaintiff, Graham, had sold land to White-Phillips Co., retaining mineral rights but granting an option for their purchase at a later date. When oil was discovered on adjacent lands, White-Phillips attempted to exercise this option but Graham refused to sell, arguing that the discovery of oil made his mineral rights more valuable than when he initially granted the lease. The court held that since there were no stipulations regarding changes in value due to external circumstances within their agreement, it must be interpreted as written; therefore ruling in favor of White-Phillips Co.. This decision reinforced contract law principles by upholding that contracts are binding regardless of subsequent events altering its perceived fairness or profitability.

In the dissenting opinion for Graham v. White-Phillips Co., Inc., Justice Stone disagreed with the majority's interpretation of a clause in an oil and gas lease contract. He argued that the lessor should not be allowed to terminate the lease if there was still production occurring, even if it was minimal or sporadic. According to him, as long as there is some level of production, it indicates that potentially profitable quantities could still be discovered and extracted from the property; thus termination would unjustly deprive lessees of their rights under such leases. The justice also contended that this interpretation aligns more closely with industry norms and expectations at that time.