In the United States v. New South Farm and Home Company case in 1915, the Supreme Court examined whether a land sale by New South Farm and Home Company to African American farmers violated federal law. The company had sold plots of land in Mississippi to black farmers from North Carolina under contracts that were allegedly fraudulent, as they misrepresented the quality of the soil and failed to disclose high transportation costs for farming equipment. The government argued this constituted mail fraud since promotional materials were sent via post. However, the court ruled against this argument stating that while misrepresentation may have occurred during sales negotiations, it did not constitute mail fraud because it was not directly related to mailing or carrying out these transactions through postal services. Therefore, even though there might be unethical business practices involved in selling lands with misleading information about their value or potential productivity; unless such activities involve misuse of mails directly leading towards fraudulent ends - they do not fall within purview of federal jurisdiction over mail frauds.

In the dissenting opinion for United States v. New South Farm and Home Company, Justice Holmes disagreed with the majority's interpretation of the statute in question. He argued that it was not intended to cover all false statements but only those made with fraudulent intent or involving moral turpitude. He believed that a broader interpretation would lead to absurd results, such as criminalizing innocent mistakes or exaggerations common in business transactions. Furthermore, he contended that if Congress had intended such a broad application of the law, they would have specified so explicitly within its text rather than leaving it up to judicial interpretation. Thus, he concluded that because there was no evidence of fraudulent intent on part of New South Farm and Home Company when making their misrepresentations about land value and fertility - merely an overstatement - they should not be held criminally liable under this statute.