In the case of Levis v. Kengla, 1897, the United States Supreme Court dealt with a dispute over land ownership in Washington D.C. The plaintiff, Levis, claimed that he had purchased a piece of property from Kengla and paid him for it but never received the deed to officially transfer ownership. He sued Kengla to obtain this deed or get his money back. However, there was no written contract between them regarding this sale; their agreement was verbal and based on trust. The court ruled in favor of Kengla because under District law at that time (the Statute of Frauds), contracts concerning real estate needed to be in writing to be enforceable unless part payment has been made or possession has been taken by purchaser with consent of seller which wasn't proven conclusively here by Levis. Therefore, since there was no written evidence supporting Levis's claim about purchasing the property from Kengla and paying him for it without receiving any title deeds as proof of transaction completion - his lawsuit against defendant failed.

The dissenting opinion in the case of Levis v. Kengla argued that the majority's decision to uphold a patent for an improvement on a machine was incorrect, as it did not meet the criteria for novelty and non-obviousness required by patent law. The justice believed that the supposed "improvement" was merely an application of existing knowledge and techniques, rather than a new invention or discovery. Therefore, he contended that granting such patents would stifle competition and innovation by allowing individuals to monopolize common knowledge under the guise of inventiveness. He also expressed concern about potential abuse of this precedent in future cases involving similar circumstances.