In the Supreme Court case of Supreme Lodge, Knights of Pythias v. Eiser in 1923, the court was tasked with determining whether or not a fraternal benefit society could change its constitution to limit benefits for members who had joined under an older version of the constitution. The plaintiff, Mr. Eiser, argued that he should be entitled to receive disability benefits as per the terms when he first became a member and paid his dues accordingly. However, after changes were made to their constitution by Knights of Pythias (the defendant), they denied him these benefits based on new rules which required additional payments for such coverage. The court ruled in favor of Mr.Eiser stating that his rights vested at the time he became a member and began paying dues according to those terms; therefore any subsequent changes made by Knights Of Pythias couldn't affect his entitlements retrospectively.

In the dissenting opinion for Supreme Lodge, Knights of Pythias v. Eiser, Justice Holmes disagreed with the majority's decision to uphold a fraternal organization's right to expel members without providing them due process. He argued that when an individual joins such an organization and pays dues, they enter into a contract which should not be arbitrarily broken by one party. In his view, these organizations have obligations towards their members and cannot simply dismiss them without cause or fair procedure. Furthermore, he contended that courts should intervene in cases where private entities violate contractual rights rather than deferring entirely to those entities' internal rules and procedures.