In the United States Fidelity and Guaranty Company v. Bray case in 1911, the Supreme Court dealt with a dispute over an insurance policy claim. The plaintiff, Bray, had taken out a burglary insurance policy on his store from the defendant company. When his store was robbed, he filed for compensation under this policy but was denied by the insurer who claimed that Bray had misrepresented facts about previous losses and burglaries at his premises when applying for coverage. This alleged misrepresentation constituted grounds to void their contract according to them. The court ruled in favor of Bray stating that even if there were inaccuracies or omissions in information provided during application process; they did not constitute fraud unless it could be proven that these were intentional attempts to deceive or materially affect risk assessment of insurer which wasn't established conclusively here. Moreover, it held that insurers cannot escape liability simply based on technicalities without proving actual fraudulent intent or material impact on risk calculation due to such misrepresentations.

In the dissenting opinion for United States Fidelity and Guaranty Company v. Bray, Justice Holmes argued that the majority's decision was not consistent with previous rulings on similar cases. He believed that the insurance company should be held liable for damages resulting from a fire caused by negligence of an employee, even if it was unintentional. The justice pointed out that in other instances where employees had accidentally caused harm while performing their duties, employers were still held responsible because they were acting within their scope of employment at the time of incident. Therefore, he disagreed with the majority's ruling which absolved USF&G Co., stating it contradicted established principles regarding employer liability and set a dangerous precedent moving forward.