In the Lazarus v. Phelps case of 1894, the U.S Supreme Court ruled on a dispute involving land ownership in Washington D.C. The plaintiff, Lazarus, claimed that he had purchased several lots from Phelps and later discovered that they were part of public streets according to city plans. He sued for fraud and misrepresentation but lost his case in lower courts due to lack of evidence proving intentional deception by Phelps. Upon appeal to the Supreme Court, it was determined that there was no error in these rulings as there wasn't sufficient proof showing fraudulent intent or false representations made by defendant during sale negotiations. Furthermore, since Lazarus failed to exercise proper diligence before purchasing property which could have revealed its status as public street area through readily available city maps and records; he couldn't claim damages based on ignorance or mistake about facts which were accessible and knowable with reasonable effort.

The dissenting opinion in the Lazarus v. Phelps case argued that the majority's decision to uphold a lower court ruling, which allowed for an individual to be held liable for debts incurred by their spouse without their knowledge or consent, was unjust and violated principles of equity. The dissenting justices contended that it was unfair to hold someone responsible for a debt they did not personally incur or agree to pay back. They also expressed concern about potential abuses of this rule, as unscrupulous individuals could potentially rack up large amounts of debt in another person's name without their knowledge or consent and then leave them with the bill. Furthermore, they pointed out that such a rule could have particularly harsh consequences for women who were traditionally less involved in financial matters than men at the time.