In the case of Holmes v. Conway in 1915, the United States Supreme Court dealt with a dispute over land ownership and mineral rights. The plaintiff, Thomas J. Holmes, claimed that he had purchased a piece of property from James A. Conway and his wife but later discovered that they did not own the mineral rights to it as they had previously asserted during negotiations for sale; these were owned by another party altogether who was extracting minerals from beneath the surface without his consent or knowledge. Holmes sued for damages on grounds of fraud and misrepresentation since he believed he was buying both surface and subsurface rights while only receiving one part - an incomplete transaction which significantly devalued his investment. The court ruled in favor of Mr.Holmes stating that even though there wasn't any explicit mention about mineral rights being included in their agreement, it could be reasonably inferred based on common understanding at time regarding such transactions where unless specifically excluded or reserved by seller, all aspects (surface/subsurface) are assumed to be transferred upon sale.

In the dissenting opinion for Holmes v. Conway, it was argued that the majority's decision to uphold a lower court ruling denying Mr. Holmes' claim against his former employer, Mr. Conway, was incorrect due to an erroneous interpretation of contract law principles and misapplication of precedent cases. The dissenting justices believed that there should have been more consideration given to whether or not there had been a breach of implied contractual obligations by Mr. Conway towards his employee, which could potentially warrant compensation for damages suffered by Mr.Holmes as a result thereof.