In the case of Potts v. Creager in 1894, the United States Supreme Court ruled on a dispute involving land ownership and mineral rights. The plaintiff, Potts, had purchased land from Creager but later discovered that there were valuable coal deposits underneath it. He sued to have his purchase rescinded on grounds of fraud because he believed that Creager knew about these deposits but did not disclose this information during their transaction. However, the court found no evidence that Creager was aware of the coal at time of sale or intentionally concealed its existence from Potts. Therefore, they held that there was no fraudulent misrepresentation involved in this case and upheld the original sale agreement between both parties.

In the dissenting opinion for Potts v. Creager, Justice Brewer argued that the majority's decision to uphold a lower court ruling in favor of Creager was incorrect because it failed to consider important elements of contract law. He contended that when Potts agreed to purchase land from Creager, he did so under the assumption that there were no outstanding liens or encumbrances on it. When this turned out not to be true, Potts rightfully refused payment and sought legal recourse. According to Justice Brewer, by ignoring these facts and focusing solely on whether or not Potts had received a deed before discovering the lien (which he hadn't), the Court was effectively allowing sellers like Creager to misrepresent their property without consequence - an outcome which undermined basic principles of fairness and honesty in business transactions.