In the case of Washington Home for Incurables v. American Security and Trust Company, 1911, the Supreme Court dealt with a dispute over a will's interpretation. The testator had left his estate to establish an institution "for the care and maintenance of incurable patients in medicine and surgery." A disagreement arose about whether this meant that only those who were medically diagnosed as incurable could be admitted or if it included individuals who were chronically ill but not necessarily deemed incurable. The court ruled that the term "incurables" was used in its broadest sense by the testator, meaning anyone suffering from chronic diseases or conditions which are either beyond complete recovery or very slow to improve should be considered eligible for admission into such an institution. Therefore, it did not strictly limit admittance to those with medical diagnoses deeming them 'incurably' ill.

In the dissenting opinion for Washington Home for Incurables v. American Security and Trust Company, it was argued that the majority's decision to uphold a lower court ruling - which allowed a charitable trust to be modified after its creator's death - undermined the fundamental principles of trust law. The dissenting justices believed that once a trust has been established by an individual, its terms should remain inviolable unless they are impossible or illegal to fulfill. They contended that allowing changes based on perceived shifts in societal needs or values could lead to abuses and misinterpretations of donors' original intentions. Furthermore, they expressed concern about potential negative impacts on future philanthropy if individuals cannot have confidence their wishes will be respected after their deaths. Therefore, these justices disagreed with the majority’s interpretation of cy pres doctrine (a principle allowing courts to modify trusts) as overly broad and potentially harmful.