In the King v. Doane case of 1890, the U.S. Supreme Court ruled in favor of plaintiff Henry King, who had sued Charles H. Doane for alleged breach of contract regarding a land sale agreement between them. The dispute arose when Doane failed to fulfill his contractual obligations after receiving payment from King for lands located in Kansas and Nebraska that were part of a railroad grant by Congress to the St Joseph & Denver City Railroad Company (SJ&DC). The court held that since SJ&DC was authorized by Congress to sell these lands as per their charter, they could legally convey title through contracts such as those made with intermediaries like Doane or directly with buyers like King. Therefore, it affirmed lower courts' judgments awarding damages to King due to non-delivery of titles by Doane despite full payment.

The dissenting opinion in the case of KING v. DOANE, 1890, argued that the majority's decision was inconsistent with previous rulings and principles of equity. The dissent contended that a mortgagee should not be allowed to purchase property at their own sale without first paying off all existing liens on the property. This would ensure fairness for other lienholders who may otherwise lose out if the mortgagee were permitted to buy back their own mortgaged property at a reduced price while still holding onto its original debt obligation. Furthermore, it was pointed out that allowing such practices could potentially encourage fraudulent behavior by enabling mortgagees to manipulate sales in order to acquire properties cheaply and unfairly disadvantage other creditors or lienholders.