In the 1915 case of HAPAI v. BROWN, a Hawaiian woman named Mary Hapai sued her former employer, William Brown, for breach of contract. She claimed that she had been hired as a domestic servant under an oral agreement and was to be paid $15 per month but was dismissed without cause before the end of the first month and not fully compensated for her work. The Supreme Court ruled in favor of Ms. Hapai stating that even though there was no written contract between both parties, an oral agreement is still legally binding if it can be proven to exist beyond reasonable doubt.

In the dissenting opinion for HAPAI v. BROWN, 1915, it was argued that the majority's decision to uphold a law prohibiting private schools from teaching foreign languages violated individual rights and liberties. The dissenters believed that such a ban infringed upon personal freedoms of speech and education protected by the Constitution. They contended that parents should have the right to decide what language their children are taught in at school without interference from government legislation. Furthermore, they disagreed with the majority's assertion that this law served public interest or welfare; instead, they saw it as an unnecessary intrusion into private life and educational choices which could potentially lead to further restrictions on civil liberties if left unchallenged.