In the case of Todok et al. v. Union State Bank of Harvard, Nebraska, et al., 1929, the Supreme Court dealt with a dispute over land ownership and mortgage payments between two parties: Todok and his wife (plaintiffs), who were immigrants from Russia; and Union State Bank of Harvard (defendant). The plaintiffs claimed that they had been misled into signing a contract in English which they did not understand due to their limited knowledge of the language. They argued that this resulted in them unknowingly agreeing to pay an excessive amount for a piece of farmland owned by the bank's president. On appeal, however, the Supreme Court ruled against them stating there was no evidence proving fraud or undue influence on part of defendants while executing said contracts. Furthermore, it held that ignorance about terms does not necessarily invalidate agreements unless such ignorance is caused by fraudulent practices from other party involved.

In the dissenting opinion for Todok et al. v. Union State Bank of Harvard, Nebraska, et al., Justice Stone argued that the majority's decision to reverse and remand was incorrect because it failed to consider whether or not there had been a violation of due process in relation to the notice given about foreclosure proceedings. He contended that if proper notice had indeed been given as required by law, then any subsequent sale would be valid regardless of whether or not an opportunity for redemption was provided after judgment but before sale. Furthermore, he asserted that even if such an opportunity were necessary under state law (which he did not believe it was), failure to provide one would still constitute only a procedural error rather than a constitutional violation warranting federal intervention.