We re-examine the evidence for the existence of ultra-massive (M > 1.1 M_sun) white dwarfs based on gravitational redshift of white dwarfs in common proper motion binaries or in clusters, on parallax measurements, on orbital solutions, and, finally, on the analysis of hydrogen line profiles. We conclude that the best evidence is largely based on the analysis of Balmer line profiles although the companion to the A8V star HR 8210 is a compelling case made initially using the large binary mass function and confirmed by an analysis of the Lyman line spectrum. The confirmation and identification of high-mass white dwarfs, more particularly non-DA white dwarfs, using parallax measurements may prove critical in establishing the population fraction of these objects and in constraining the high-end of empirical initial-mass to final-mass relations. The existence of a substantial population of ultra-massive white dwarfs supports the concept of a steeper initial-mass to final-mass relations linking 6 M_sun progenitors with approximately greater than 1.1 M_sun white dwarfs.