In the Supreme Court case of Supreme Council of The Royal Arcanum v. Behrend in 1917, the court ruled on a dispute involving an insurance policy issued by the fraternal benefit society, The Royal Arcanum. Mr. Behrend had been paying dues for his life insurance policy but after he died, his beneficiary was denied benefits because Mr. Behrend's local council had been suspended due to non-payment of its own dues to the supreme council at the time of his death. However, it was found that Mr.Behrend himself wasn't aware about this suspension and continued paying premiums till his death.The U.S Supreme Court held that since there were no provisions in either constitution or laws which provided for forfeiture of individual rights upon suspension or expulsion from membership due to nonpayment by their councils,the beneficiary could not be deprived off her claims as long as she paid all legal assessments required under contract with defendant.This decision emphasized on importance given to contractual obligations over internal rules and regulations within organizations.

In the dissenting opinion for Supreme Court case, Supreme Council of the Royal Arcanum v. Behrend, Justice Holmes disagreed with the majority's decision to uphold a fraternal benefit society's right to increase dues without member consent. He argued that members had entered into contracts with set terms and conditions when they joined these societies, including fixed rates of payment. Therefore, any unilateral changes made by such organizations were not only unfair but also violated contractual obligations. Furthermore, he contended that if members could be subjected to arbitrary increases in their payments at any time without their agreement or prior knowledge, it would render their contracts meaningless and provide no security or certainty whatsoever about future financial commitments. This view was based on his belief in upholding individual rights against potential abuses by powerful institutions.