Harter v. Kernochan was a United States Supreme Court case that addressed the issue of whether a tenant in possession of a property had the right to remove improvements made to the property by the landlord. The case was brought by the tenant, Harter, who had leased a property from Kernochan. During the lease, Harter had made improvements to the property, such as installing a new roof and making other repairs. When the lease expired, Kernochan demanded that Harter remove the improvements, but Harter refused. The Supreme Court ultimately ruled in favor of Harter, finding that the tenant had the right to keep the improvements made to the property. The Court reasoned that the tenant had a right to the possession of the property, and that the improvements were made in good faith and with the expectation that the tenant would be able to keep them. The Court also noted that the tenant had paid for the improvements, and that the landlord had not been harmed by the tenant's actions. The Court concluded that the tenant had a right to keep the improvements, and that the landlord could not demand their removal.

Justice Field delivered the dissenting opinion in Harter v. Kernochan, arguing that the majority's decision was contrary to established precedent and would lead to a great deal of uncertainty for future cases. He argued that under existing law, when an individual has obtained possession of property through fraud or mistake, they are not entitled to retain it unless they can show some form of title or right superior to that which is held by the rightful owner. In this case, he noted that there had been no evidence presented showing any such title or right on behalf of either party; thus, he concluded that the lower court's ruling should have been upheld and Kernochan should be allowed to recover his property from Harter. Justice Field further argued against allowing equitable relief in these types of cases as it could open up a Pandora’s box for other similar disputes where one party may attempt to use equity as a means for obtaining something without having legal rights thereto.