In Robert Holliday et al. v. Joseph N. Batson et al., the Supreme Court of the United States heard a case involving an appeal from a decision of the Circuit Court for Washington County, Maryland concerning a dispute over land ownership and title rights in that county. The appellants argued that they had acquired title to certain lands by virtue of their purchase from one William Hatton, who was alleged to have held legal title at the time he sold them; however, it was contended by respondents that Hatton did not hold such legal title when he conveyed his interest in said lands to appellants because his deed had been obtained through fraud and misrepresentation on his part as well as collusion between him and other parties involved in this transaction. The Supreme Court ultimately found for respondents on grounds that there were sufficient facts presented which showed fraudulent conduct on behalf of all parties involved with respect to obtaining said deed; thus, holding void any purported transfer or conveyance made under such circumstances regardless if actual notice or knowledge thereof existed among those claiming interests therein at time same occurred.

In Robert Holliday et al. v. Joseph N. Batson et al., the dissenting opinion argued that a deed of trust was not valid because it did not contain an express agreement to pay off the debt in full, and therefore should be considered voidable by either party under Virginia law at the time. The majority opinion had held that such a deed was binding on both parties regardless of whether or not there was an explicit agreement for repayment, but Justice Daniel dissented from this view and argued that without any clear language regarding payment, neither party could be bound to fulfill their obligations as stated in the deed. He further noted that if one side were allowed to enforce its terms while denying enforcement of those same terms against themselves, then it would create an unfair situation where only one side is able to benefit from their contract with impunity while leaving no recourse for redress available to the other party involved in said contract.