In the 1943 case, Securities and Exchange Commission v. C.M. Joiner Leasing Corporation et al., the U.S Supreme Court ruled in favor of the SEC, stating that oil drilling leases sold by Joiner's company were indeed securities under federal law and thus subject to regulation by the SEC. The court held that these lease contracts constituted an investment contract as they involved an investment of money with profits to come solely from efforts of others (the drilling operations). This decision expanded the definition of "securities" beyond stocks and bonds to include a broader range of investments such as oil leases or other similar types of contractual agreements where investors expect profits primarily from others' efforts.

In the dissenting opinion for SECURITIES AND EXCHANGE COMMISSION v. C. M. JOINER LEASING CORPORATION et al., Justice Robert H. Jackson argued that the majority's decision expanded the definition of a security too broadly, which could potentially lead to an overreach of federal regulatory power in areas traditionally governed by state law such as real estate transactions and other business contracts not typically considered securities under previous interpretations of the Securities Act. He contended that this broad interpretation would create uncertainty in commercial transactions and hinder economic growth due to fear of potential litigation or regulatory action from parties involved in ordinary business dealings who may unknowingly violate securities laws because they are now deemed securities dealers or brokers according to this new expansive interpretation.