Pickhardt v. Merritt is a Supreme Court case from 1891 that dealt with the issue of whether a tenant was entitled to compensation for improvements made to a leased property. The plaintiff, Pickhardt, had leased a property from the defendant, Merritt, and had made improvements to the property during the course of the lease. When the lease expired, Pickhardt sought compensation for the improvements he had made. The Supreme Court held that Pickhardt was entitled to compensation for the improvements he had made, as the improvements had increased the value of the property and had been made with the consent of the landlord. The Court also held that the tenant was entitled to compensation for the improvements even if the lease had expired, as the tenant had a right to the value of the improvements he had made. The Court also held that the tenant was not entitled to compensation for any improvements that had been made without the consent of the landlord.

In the Supreme Court case of Pickhardt v. Merritt, Justice Holmes wrote a dissenting opinion in which he argued that the majority had incorrectly interpreted the law and failed to consider relevant facts. He noted that while it was true that Mr. Pickhardt had been injured by an animal owned by Mr. Merritt, there were other factors at play as well; namely, that both parties were aware of the risks associated with keeping such animals on their property and thus should have taken steps to mitigate those risks accordingly. Furthermore, Justice Holmes argued that even if one party did not take reasonable precautions against potential harm from an animal they owned or kept on their premises, this did not necessarily mean they could be held liable for any injuries caused by said animal—especially when both parties knew about these risks beforehand and took no action to prevent them from occurring in the first place. Ultimately, Justice Holmes concluded his dissent by noting how important it is for courts to properly interpret laws so as not to create unfair outcomes or unjustly punish individuals who may have acted reasonably given all available information at hand prior to any incident taking place between two parties involved in a dispute over liability for damages caused by an animal-related injury or accident