In the case of Kent v. Lake Superior Ship Canal, Railway and Iron Company in 1891, the U.S Supreme Court ruled on a dispute over land ownership rights. The plaintiff, Kent, claimed that he had purchased certain lands from the State of Michigan which were subsequently sold to the defendant company by Congress. The court held that while both parties believed they had valid titles to the property at issue; only one could be correct. It was determined that when Michigan became a state it gained title to all unsold lands within its borders unless those lands were specifically reserved by Congress for other purposes - something not done in this instance before or after statehood was granted. Therefore, any subsequent sale of these same lands by Congress would have been invalid as they no longer owned them upon Michigan's admission into Union as a state. As such, Kent’s purchase from Michigan gave him rightful ownership and his claim against Lake Superior Ship Canal, Railway and Iron Company was upheld.

In the dissenting opinion for Kent v. Lake Superior Ship Canal, Railway and Iron Company, Justice Lamar disagreed with the majority's interpretation of the contract between both parties. He argued that there was no breach of contract by Lake Superior Ship Canal, Railway and Iron Company as they had fulfilled their obligations to transport iron ore from a specific location at an agreed price. According to him, any changes in circumstances such as increased costs or difficulties in transportation should not be considered a violation of the agreement since these were risks assumed by both parties when entering into it. Furthermore, he contended that if every change in circumstance could potentially lead to a lawsuit for breach of contract then this would create uncertainty and instability within business relationships which is contrary to public policy interests.