This case involved a mortgage foreclosure action brought by Merrill against Dawson and subsequent purchasers of slaves that had been pledged as collateral for notes Merrill had endorsed. The lower court ruled for Merrill, ordering the respondents to pay over $18,000 or face foreclosure and loss of the slaves or their value, plus accounting for hire. On appeal, the Supreme Court affirmed, holding that the mortgage was validly executed and recorded well before the respondents acquired the slaves, that objections to deposition evidence and timing were meritless, and that the lower court's valuation and hire calculations were appropriate. The Court rejected arguments that the mortgage was fraudulent due to the mortgagor's retained possession, noting the recording provided notice, and found no error in presuming a child was born to one of the mortgaged women or in the net hire assessment.

propertyprocedure

In this admiralty case, the owners and master of the steamship Globe filed a libel in rem against the schooner Lucy Ann and its cargo seeking compensation for salvage services after assisting the vessel when it ran aground. The District Court awarded salvage equal to one-fifth of the value of the vessel and cargo. On appeal by the schooner's master, the Supreme Court dismissed the case for lack of jurisdiction. The Court reasoned that the amounts at issue in salvage claims against individual owners or consignees each fell below the $2,000 threshold required for appellate review, and the master lacked authority to represent the separate cargo interests on appeal without specific authorization.

procedure

In Conrad v. Griffey, Griffey sued Conrad over the construction of a sugar-cane mill, with Conrad defending on grounds that the work and materials were defective. At trial, after Conrad introduced prior inconsistent statements by a witness who had testified in support of the mill's quality, Griffey sought to introduce the witness's later consistent statements, which the lower court admitted over Conrad's objection. The Supreme Court reversed, ruling that subsequent consistent statements by an impeached witness are generally inadmissible because they lack the requisite independence from potential bias or motive to rehabilitate credibility and do not qualify as substantive evidence. The Court based its decision on prevailing general principles of evidence, noting a trend in federal and many state courts toward exclusion of such testimony when made after the impeaching statements.

procedure

This case involved a petition for a writ of mandamus filed by the executrix of James Reeside against the Secretary of the Treasury, seeking to compel the entry of a credit and payment of $188,496.06 based on a jury verdict from an earlier federal lawsuit in Pennsylvania where a set-off was pleaded against the United States on post-office contracts. The Circuit Court dismissed the petition, and the Supreme Court affirmed that decision. The Court reasoned that the docket minutes from the prior case did not constitute a final judgment of indebtedness against the United States that could be enforced by mandamus, as Pennsylvania procedure in set-off cases required a scire facias to establish such a judgment. Additionally, even assuming a valid judgment existed, no mandamus could issue because the Constitution prohibits drawing funds from the Treasury without a congressional appropriation, and no such appropriation had been made for this claim.

procedurefederal power

This case involved grandchildren of Joseph Simon claiming that a conveyance of partnership lands from his estate's executrix to Simon Gratz was fraudulent, seeking to void it and require accounting for sales and rents. The lower court found the conveyance fraudulent but, due to subsequent sales to innocent purchasers, ordered Gratz to pay the full value without deductions. On appeal, the Supreme Court reversed, holding that there were no strong indications of fraud given the family connections, the consideration paid, and equitable circumstances in the family settlement, and remanded the case to dismiss the bill or adjust to enforce the agreement while accounting for claims.

propertyfamily law

This case involved an action on an official bond against a collector of the port of New Orleans for failing to pay over duties collected for the United States and make proper returns, including treasury notes received and later lost or altered after cancellation. The lower court instructed the jury that the collector was not liable for two altered notes accepted without knowledge of the alteration or for notes that were cancelled and prepared for mailing but lost before reaching the post office, leading to a partial verdict for the government. The Supreme Court held both instructions erroneous, ruling that the collector remained liable under his bond and official duties for accepting altered notes and for the lost notes until they were properly transmitted to the Treasury as required by law and circulars. The Court reasoned that the collector acted as a government officer, not a mere bailee, and was responsible for ensuring valid payments and following transmission procedures to prevent fraud or loss, with damages to be proven on remand. The judgment was reversed and the case remanded for a new trial.

federal powerbusiness & regulatorytaxesprocedure

This case involved importers challenging extra duties and a penalty assessed by a customs collector after railroad iron was appraised more than ten percent above its invoice value. The Supreme Court affirmed the lower court's judgment ordering the collector to refund the amounts paid, holding that the appraisal process was invalid. The Court reasoned that federal statutes required the appraisers to value the iron as of the date it was procured abroad rather than the later invoice date, that both appraisers had to personally examine the goods, and that a merchant appraiser could not be removed and replaced without legal authority because such appraisers functioned as impartial umpires in disputes between the government and importers.

business & regulatorytaxesfederal power

This case involved an importer challenging the collection of excess customs duties on goods purchased abroad, where the collector appraised the goods at a higher value based on the time of shipment rather than the actual purchase price, which would have triggered a penalty. To avoid the penalty, the importer added to the invoice value and paid the increased duties under protest before suing to recover the excess. The court ruled in favor of the importer, allowing recovery of the duties. The core reasoning was that the payment was involuntary, resulting from an illegal appraisal method and moral duress to regain the goods, and thus recoverable under the relevant statute or common law when made under protest.

taxesbusiness & regulatoryfederal power

The case involved a writ of error from the Connecticut Supreme Court challenging state legislation from 1818 and 1841 that discontinued a ferry across the Connecticut River and shifted related rights to a bridge company, with East Hartford claiming these acts impaired a contractual grant of ferry privileges dating back to the 1600s and 1783. The U.S. Supreme Court affirmed the judgment below, restraining East Hartford from operating the ferry and rejecting the constitutional challenge. The Court reasoned that the original grants were legislative acts concerning public interests and municipal corporations rather than contracts between the state and private parties, so they remained subject to later modification by the legislature without violating the Contract Clause. It further noted that the towns held such privileges only for public purposes and lacked the attributes of protected private property interests.

federal powerproperty

This case concerns the validity of letters patent issued in 1834 for improvements in steam engines to propel vessels and carriages on land, including questions about whether the specification was adequately incorporated into the patent and whether multiple connected inventions could be covered by one patent. Upon reargument after prior proceedings, the Supreme Court affirmed its earlier ruling that the patent was valid and not defective. The Court reasoned that the 1793 Patent Act permitted voluntary incorporation of the specification by reference, making it part of the patent itself and providing a sufficient description of the invention, and that the improvements were connected in design and operation rather than independent. The judgment of the Circuit Court was affirmed, with costs and interest.

business & regulatoryproperty

The case involved importers who sought to recover excess customs duties paid on sugar shipments that arrived in reduced quantities due to drainage and waste during transit. The collector had assessed duties based on the full invoiced amounts shipped from abroad, but the importers argued for assessment only on the quantities that actually reached the United States. The Supreme Court affirmed the lower court's judgment allowing recovery of the excess, reasoning that revenue laws impose duties solely on imports that enter U.S. ports, as confirmed by constitutional language, statutory provisions, and precedents treating only arrived goods as subject to taxation. The Court also upheld the validity of the importers' protests for recovering duties not yet finally accounted for with the government. The decision aligned with other statutory allowances for losses like leakage or damage in similar contexts.

taxesbusiness & regulatory

This case was an ejectment action over a disputed strip of land in Mobile, Alabama, where the plaintiff claimed title under a 1757 French grant confirmed by Congress and a later patent, while the city claimed it as part of the historic 'bakehouse lot' granted to it by an 1824 act of Congress. The Supreme Court affirmed the state court's judgment for the city, holding that federal land officers lacked authority to resolve conflicting titles (as opposed to mere locations) under the relevant statutes and that the city's grant was a perfect title not subject to their adjudication. The core reasoning was that boundary disputes like the southern line of the bakehouse lot were properly tried in state court under general principles, with monuments controlling distances, and that the officers' actions could not override the city's subsequent congressional grant or settle title in this context.

propertyfederal powerprocedure

The case involved an appeal by Barrow from a lower court judgment in a contract dispute over a sale of goods governed by Louisiana law, where the plaintiff sought damages and the defendant challenged aspects of the trial proceedings and the award. The Supreme Court affirmed the judgment, including an award of interest on the verdict. The core reasoning was that no exception regarding jury instructions on tender of payment had been properly preserved in the record below, creating a presumption that the trial court had correctly addressed it, and that post-1839 Louisiana statutes and case law permitted interest on unliquidated contract claims from the time of judicial demand. A secondary challenge regarding the form of demand was also rejected as unsupported by the facts.

procedurebusiness & regulatory

This case concerned whether the master of a U.S. vessel violated an 1803 federal statute by failing to deposit the ship's register and other papers with the U.S. consul upon briefly touching at the port of Kingston, Jamaica. The statute imposed a $500 penalty on masters who refused or neglected to deposit papers on arrival at a foreign port. The Supreme Court held that the master had not violated the law and no penalty applied. The Court reasoned that penal statutes must be strictly construed with doubts resolved in favor of the defendant, and that the term 'arrival' refers only to a vessel coming to port for commercial business with the intent and opportunity to enter and clear, rather than any temporary touching at a port.

criminal lawbusiness & regulatory

The case concerned the validity of a municipal tax sale in Washington, D.C., where the city sold all twenty lots assessed to the Washington Tontine Company to collect unpaid taxes, even though the first two lots alone fetched more than the total amount due. The Supreme Court reversed the lower court's judgment upholding the sale. It held that the governing statutes, including the 1824 act and prior charters, permitted the city to sell only as many lots as necessary to satisfy the taxes and required stopping once that amount was reached. The Court reasoned that the language granting authority to sell one or more lots did not confer discretion to sell all when fewer would suffice, consistent with its earlier decision in Corporation of Washington v. Pratt and the principle that tax sales must strictly comply with statutory limits.

taxesproperty

The case involved a dispute over a fence built by defendant Irwin on land adjacent to plaintiffs' warehouse in Alexandria, which the plaintiffs claimed obstructed a public highway or strand that had been used by the public for over thirty years, constituting both a public and private nuisance. The plaintiffs sought an injunction to remove the fence and prevent further obstruction, alleging the land had been dedicated to public use. The lower court found that a public highway existed next to the warehouse and issued a permanent injunction ordering removal of the fence within a nineteen-foot-wide area. The Supreme Court reversed, holding that the evidence did not establish a dedication to the public or an adverse, exclusive use sufficient to create a public highway by prescription, as the use had been with the owner's consent and for private purposes as well. The Court further noted that an injunction is an extraordinary remedy not appropriate without clear proof of the claimed rights, and remanded with instructions to dismiss the bill.

propertytorts & liabilityprocedure

This case involved a buyer who paid $1,800 for land in Wisconsin and received a deed with covenants of seizin and right to convey, only to later discover the sellers lacked valid title. The buyer sued in New York federal court using assumpsit for money had and received, relying on the deed's promises. The court held that New York law governed the form of action, requiring assumpsit rather than covenant due to the instrument's lack of a formal seal, and that a covenant of seizin is breached upon delivery if title is defective, without needing to allege eviction. It further ruled that the sellers' power of attorney to their agent was broad enough to authorize a deed with warranty covenants, based on its language empowering the agent to sell and convey on terms he deemed best, plus the parties' subsequent conduct. The Supreme Court affirmed the judgment for the buyer.

propertyprocedure

The case West v. Smith was a chancery proceeding filed in the Circuit Court for the District of Columbia to recover a $3,000 legacy bequeathed by Joseph Mandeville to Ellen Mandeville (now Smith), involving disputes over estate administration, executor commissions, real property sales, and objections to a commissioner's report. The Supreme Court first overruled a claim that James Mandeville, a Virginia legatee, must be joined as a party, citing lack of jurisdiction over out-of-state persons and property as well as sufficient assets within Alexandria County to satisfy the claims. It then rejected exceptions to the executor's $84.29 commission on a specific legacy of slaves and furniture, finding authority for such allowances under Virginia or Maryland law and settled practice, and held that no implied contract supported setting off rent claims against legacies where occupation was adverse. The Court affirmed the decree below, noting that independent creditor and legatee claims could be resolved separately without delaying final judgment on the rest.

propertyprocedure

The case involved a dispute over whether an insurance policy on a factory covered a loss from a fire caused by lamps in the picking-room, contrary to written representations made in the original 1834 application by a prior owner (Stearns) that were referenced and adopted in later renewals and transfers of the policy to the plaintiffs. The court first ruled that parol evidence was admissible to identify the specific representations referenced in the policy without varying its terms, and that the plaintiffs were bound by those representations if they had adopted them, making the policy void due to the undisclosed material risk. However, because the bill of exceptions indicated the jury had been instructed on an alternative ground if the first failed, creating a potential record defect even though the verdict was taken pro forma, the Supreme Court reversed the judgment below and remanded for correction of the record and further proceedings consistent with its opinion on the merits.

business & regulatorypropertyprocedure

This case concerned a buyer's attempt to rescind an 1836 auction sale of mill properties after discovering that the auctioneer had engaged in by-bidding, artificially inflating the final price from around $20,000 to $40,000. The Supreme Court found that the sellers had authorized the auction and benefited from the inflated price obtained through fictitious bids, rendering the sale fraudulent under principles of equity. The Court reversed the lower court's dismissal, set aside the sale, and ordered the buyer to retain the property at the fair bid price of $20,000 while requiring refund of the excess amount paid plus interest and cancellation of related notes. It also awarded costs to the buyer. The ruling rested on evidence that real bids did not exceed $20,000 and that the auctioneer's actions were not for his own account but to boost the price and commissions.

propertybusiness & regulatory