In the 1914 case of Wathen v. Jackson Oil & Refining Company, the United States Supreme Court addressed a dispute over land ownership and oil drilling rights in Kentucky. The plaintiff, Wathen, claimed that he had purchased land from an individual who did not have legal title to sell it because it was actually owned by his wife's estate. Despite this alleged lack of authority to sell the property, Jackson Oil & Refining Company began drilling for oil on the disputed land after purchasing it from another party who bought it from the same seller as Wathen. The court ruled in favor of Jackson Oil & Refining Company based on their good faith belief that they were buying from a legitimate owner and their significant investment into developing the property before learning about any potential issues with its sale.

The dissenting opinion in the Wathen v. Jackson Oil & Refining Company case argued that the majority's decision was inconsistent with previous rulings and failed to consider important factors. The dissent emphasized that a contract should not be deemed invalid simply because it is disadvantageous or unfair to one party, as long as both parties entered into it freely and without fraud or duress. It also pointed out that there was no evidence of such misconduct in this case. Furthermore, they disagreed with the majority's interpretation of "reasonable time" for performance under an open-ended contract, arguing instead for a more flexible approach based on circumstances rather than fixed rules. They believed that by ignoring these principles, the court had unjustly deprived the defendant company of its contractual rights.