In the Iron Gate Bank v. Brady case of 1901, the U.S Supreme Court dealt with a dispute over a promissory note issued by Iron Gate Bank to Brady. The bank claimed that it had mistakenly paid out more money than was due on the note and sought reimbursement from Brady for this excess amount. However, Brady argued that he was not obligated to repay any additional funds because he had already fulfilled his obligations under the terms of the original agreement. The court ruled in favor of Iron Gate Bank, stating that even though there may have been an error made during payment processing, this did not absolve Brady from his responsibility to return any surplus funds received beyond what was stipulated in their initial contract.

The dissenting opinion in the Iron Gate Bank v. Brady case argued that the majority's decision was incorrect because it failed to consider the full implications of its ruling on future cases. The dissenting justices believed that by allowing a bank to sue for damages, even though it had not suffered any actual harm, set a dangerous precedent. They contended that this could potentially open up floodgates for frivolous lawsuits and unjust enrichment at others' expense. Furthermore, they disagreed with the majority's interpretation of "damages," arguing instead that damages should be limited to actual losses incurred rather than potential or hypothetical ones. In their view, only those who have suffered real and tangible harm should be entitled to seek redress from courts.