In the 1890 case Martin v. Barbour, the United States Supreme Court ruled on a dispute involving land rights in Florida. The plaintiff, Martin, claimed that he had purchased land from the state of Florida which was later sold by the state to another party (Barbour). He argued this second sale was invalid as it violated his pre-existing ownership rights. However, Barbour countered that at the time of his purchase, there were no records indicating any prior sale or claim to these lands by Martin. The court sided with Barbour and upheld his ownership of the property. In its decision, it emphasized that when dealing with public lands intended for sale by states or federal government entities - such as those involved in this case - potential buyers must be able to trust official records regarding previous sales and claims over these properties. If not so assured they would face great uncertainty and risk in their transactions. Therefore if an earlier transaction is not properly recorded then subsequent purchasers cannot be held responsible for being unaware of them; nor can such unrecorded transactions invalidate later ones made in good faith based on available information.

In the dissenting opinion for Martin v. Barbour, Justice Lamar disagreed with the majority's decision to deny Martin his claim on a bond issued by Barbour County in Alabama. He argued that while it was true that the county had exceeded its statutory limit of indebtedness when issuing this bond, this fact should not invalidate an obligation willingly entered into by both parties and already partially fulfilled. Furthermore, he contended that since there was no evidence of fraud or collusion between Martin and the county officials who issued him the bond, it would be unjust to punish him for their mistake. Finally, he pointed out that if counties could simply refuse to pay debts they had legally incurred but later found inconvenient or unaffordable, then public credit would be seriously undermined.