In the 1905 case Hartman v. Butterfield Lumber Company, the U.S Supreme Court ruled in favor of Butterfield Lumber Company. The dispute arose when Hartman claimed that he had been defrauded by the lumber company and its agents who allegedly misrepresented the quality of a tract of timberland sold to him. He sought damages for this alleged fraud. However, it was found that there was no evidence to support his claim as he failed to provide any proof showing that false representations were made or relied upon during his purchase decision-making process. Therefore, due to lack of substantial evidence supporting his allegations against Butterfield Lumber Company, Hartman's claims were rejected and judgment was given in favor of the defendant - Butterfield Lumber Company.

The dissenting opinion in the Hartman v. Butterfield Lumber Company case argued that the majority's decision was incorrect because it failed to consider the full implications of its ruling on future cases. The dissent contended that by allowing a corporation to be held liable for damages caused by an employee, even when acting outside of their official duties and without explicit authorization from superiors, set a dangerous precedent. This could potentially expose corporations to limitless liability for actions they had no control over or knowledge about. Furthermore, it would discourage businesses from hiring employees due to fear of potential legal repercussions stemming from their personal conduct while off duty or not directly related with work tasks assigned by company management.