The Roehm v. Horst case in 1899 revolved around a dispute over the payment of a promissory note. The plaintiff, Roehm, had given the defendant, Horst, a promissory note for $10,000 with an interest rate of six percent per annum until paid. However, when it was due and payable on demand in New York City where both parties resided at that time; Horst refused to pay claiming he owed nothing because he had already made payments to Roehm's son who lived in Minnesota without any objection from Roehm himself. Roehm sued for recovery but lost his case at trial court level as well as appellate division which held that since there was no express prohibition against making payments elsewhere than New York City or to someone other than the holder himself; such payments were valid and discharged obligation under the note. However upon appeal by Roemh , US Supreme Court reversed these decisions stating that unless specifically agreed between parties involved ; place mentioned on instrument (promissory notes) is not just for convenience but also determines jurisdiction i.e., law governing transactions related thereto including rights & obligations arising out thereof . Therefore according to this ruling , only those payments are valid which are made either directly to holder or his authorized agent within specified jurisdiction.

In the dissenting opinion for Roehm v. Horst, Justice Harlan disagreed with the majority's interpretation of contract law and its application to this specific case. He argued that a promisee who has not provided consideration should still be able to enforce a promissory note if they are the legal holder of it at maturity. In his view, such an individual would have acquired all rights associated with that note under commercial law principles, regardless of whether or not they had given value for it initially. This position was based on established precedents in English and American jurisprudence which recognize negotiable instruments as property capable of being transferred free from equities between prior parties. Therefore, he contended that Mr.Horst’s claim against Mr.Roehm should stand because he held the notes when due even though no consideration moved directly from him to Roehm.