In the case of Haffner v. Dobrinski in 1909, the US Supreme Court dealt with a dispute over land ownership. The plaintiff, Haffner, claimed that he had purchased a piece of property from Dobrinski and had made significant improvements to it under the belief that he was its rightful owner. However, when Dobrinksi later sold the same property to another party without acknowledging Haffner's claim or compensating him for his investments into improving it, Haffner sued for damages. The court ruled in favor of Dobrinski on grounds that there was no written agreement between him and Haffner regarding any sale or transfer of ownership rights over said property; therefore, according to law at that time which required such agreements be documented in writing (Statute of Frauds), no legal transaction could have taken place as alleged by plaintiff.

The dissenting opinion in the case of Haffner v. Dobrinski argued that the majority's decision to uphold a lower court ruling, which found in favor of Dobrinski, was incorrect because it failed to consider key aspects of contract law. The dissenting justices believed that there had been a clear breach of contract by Dobrinski when he sold property that he had previously agreed to sell to Haffner. They contended that even though no formal written agreement existed between Haffner and Dobrinski, an oral agreement should have been sufficient since both parties were aware and accepting of its terms. Furthermore, they disagreed with the majority's interpretation regarding specific performance as a remedy for breach of contract cases like this one; instead arguing for damages as compensation rather than forcing compliance with original contractual obligations.