In the case of Sartor et al. v. Arkansas Natural Gas Corp., 1943, the U.S Supreme Court ruled in favor of Arkansas Natural Gas Corporation (ANGC). The plaintiffs, Sartor and others, had originally won a lawsuit against ANGC for breach of contract related to oil and gas leases on their land. However, ANGC appealed this decision arguing that there was insufficient evidence to support the claimants' allegations. The Supreme Court agreed with ANCG's argument stating that it is not within its jurisdiction to weigh evidence or determine facts but rather review whether sufficient proof has been presented at trial court level which could justify a verdict by any reasonable jury based on 'the common law or statutory rules of evidence'. In this case, they found no such substantial proof existed hence reversed the lower courts’ decisions.

In the dissenting opinion for Sartor et al. v. Arkansas Natural Gas Corp., Justice Frank Murphy argued that the majority's decision was a departure from established principles of equity jurisdiction and practice, which required clear proof before granting an injunction to prevent alleged irreparable injury or damage. He contended that there was no substantial evidence in this case to support such drastic relief, as it relied on mere conjecture and speculation about possible future harm rather than concrete facts. Furthermore, he believed that the lower court had not abused its discretion by denying an injunction because it correctly applied legal standards regarding speculative damages and potential harm to public interest if gas service were interrupted due to litigation disputes between private parties over contract rights. Therefore, he disagreed with overturning its judgment based on insufficient grounds for appellate intervention under traditional rules governing equitable remedies.