In the 1891 U.S. Supreme Court case Hoyt v. Latham, a dispute arose over land in California that was originally granted by Mexico to two individuals before it became part of the United States. The plaintiff, Hoyt, claimed ownership based on a tax sale after one of the original grantees failed to pay taxes on the property. Meanwhile, defendant Latham asserted his claim through purchase from both original grantees and their successors. The court ruled in favor of Latham because he had obtained full title from all parties with an interest in the property while Hoyt only held a partial interest due to purchasing at a tax sale for unpaid taxes by one grantee but not both. The decision clarified that under Mexican law (which still applied since it was enacted prior to California's statehood), joint grants were considered as made jointly and severally - meaning each grantee owned an undivided whole rather than just half of the land - so any subsequent transfer required consent from all parties involved.

The dissenting opinion in the Hoyt v. Latham case argued that the majority's decision was incorrect because it failed to consider important aspects of contract law. The dissenting justices believed that Mr. Hoyt had a valid and enforceable contract with Mr. Latham, despite any potential misunderstandings or miscommunications between them about its terms or conditions. They also disagreed with the majority's interpretation of certain legal principles related to contracts, such as consideration and mutual assent, arguing that these were not applied correctly in this case. Furthermore, they contended that even if there were ambiguities in the contract, these should have been resolved in favor of enforcing it rather than voiding it entirely as per standard practice under common law rules for interpreting contracts.