In the case of Johnson v. Gearlds in 1913, the U.S Supreme Court dealt with a dispute over land ownership. The plaintiff, Johnson, claimed that he had purchased a piece of property from an individual who was not legally entitled to sell it because they did not own it at the time of sale. This person later acquired legal title to this property and sold it again to another party (Gearlds). The court ruled in favor of Gearlds on grounds that his purchase was made after the seller had obtained legitimate title to the property and therefore he held superior claim over Johnson's earlier but flawed transaction. Essentially, this ruling upheld that subsequent good faith purchasers for value without notice hold better title against prior purchasers with defective titles.

The dissenting opinion in the Johnson v. Gearlds case argued that the majority's decision to uphold a lower court ruling, which found Mr. Johnson guilty of contempt for refusing to answer questions during a grand jury investigation, was incorrect. The dissent held that Mr. Johnson had not been given adequate opportunity to explain his refusal and therefore should not have been held in contempt without further examination into whether he had valid reasons for doing so under his Fifth Amendment rights against self-incrimination. They believed this constituted an infringement on individual liberties protected by the Constitution and expressed concern about potential misuse of power by courts if such decisions were allowed to stand unchallenged.