In Throckmorton v. Holt, the U.S. Supreme Court ruled on a dispute over land ownership in California that had been previously decided by the Board of Land Commissioners and affirmed by both district and circuit courts. The plaintiff, Throckmorton, alleged fraud in the original case and sought to have it reopened for reconsideration based on new evidence he claimed proved his right to the property. However, the court held that res judicata (a matter already judged) applied; once a case has been decided upon its merits by a competent court, it cannot be reopened except under very specific circumstances such as clerical error or lack of jurisdiction - neither of which were present here. Fraud allegations could not serve as grounds for reopening because they should have been raised during initial proceedings if suspected at all; allowing otherwise would undermine finality in legal decisions.

In the dissenting opinion for Throckmorton v. Holt, it was argued that the majority's decision to deny relief based on fraud contradicted previous rulings of the court and common law principles. The dissenting justices believed that a judgment obtained by fraud should not be immune from attack in equity, regardless of whether it is a federal or state court judgment. They contended that there are numerous precedents where courts have granted relief against fraudulent judgments and decrees, even when they were rendered by competent jurisdiction. Furthermore, they pointed out that if such protection were given to fraudulent judgments due to respect for finality, then justice would be sacrificed at its altar. Therefore, according to them denying an equitable remedy in cases like this could potentially encourage dishonest practices during litigation as parties may resort to deceit knowing their actions will go unpunished once a judgement has been made.