The case concerned whether a deed signed, sealed, and delivered by merchant William Robb on May 30, 1800, to secure a creditor, but acknowledged and enrolled on June 14, qualified as an act of bankruptcy under the federal Bankruptcy Act of April 1800, which took effect June 1 and allowed assignees to recover assets from fraudulent conveyances. Robb was declared bankrupt shortly after the deed's acknowledgment, and his assignees sued Gabriel Wood to recover funds received under it. The Supreme Court held that the deed was complete on May 30 under common law, as the Maryland statute requiring acknowledgment and enrollment affected only the passing of the estate, not the instrument's status as a deed. Therefore the conveyance predated the bankruptcy law and did not constitute an act of bankruptcy, so the assignees could not recover.
The case concerned whether an absolute bill of sale for a slave, recorded but with possession remaining with the seller, was valid against a creditor who later seized the slave under an execution. Thomas Hamilton sued Russell, the creditor's agent, in trespass after the seizure, but the trial court instructed the jury that the sale was fraudulent if possession did not accompany the deed, leading to a verdict for the defendant. The Supreme Court affirmed, holding that under the governing Virginia statute (modeled on the statutes of Elizabeth), an unconditional bill of sale without immediate delivery of possession constitutes fraud in law as to creditors, not merely evidence of fraud. The Court distinguished conditional conveyances and rejected the plaintiff's requested jury instruction as abstract and inapplicable.
In Resler v. Shehee, the case involved an appeal from a circuit court decision rejecting a defendant's special plea filed after the period for doing so as of right, in an action concerning malice and probable cause in a prior prosecution. The Supreme Court affirmed the lower court's judgment. It reasoned that the facts alleged in the plea could have been introduced as evidence under the general issue, and that at a term subsequent to the office judgment, the admission of a special plea was a matter of the trial court's discretion under Virginia practice, which federal circuit courts were to follow absent their own contrary rules; the court below had exercised that discretion soundly.
This case involved a criminal defendant seeking compulsory process to secure members of Congress as witnesses in his defense. The court refused the motion for a letter or other accommodation excusing congressional members from the obligations of a subpoena. Justice Chase explained that the Constitution grants every person charged with an offense the right to compulsory process and provides no exemption for members of Congress from subpoenas in criminal cases. The court observed that questions about enforcing attendance, such as through attachment, would arise only after service and could be resolved based on any satisfactory reasons for nonattendance.
The case O'Harra v. Hall concerned whether oral testimony could be introduced to modify the terms of a written contract in a common law proceeding. The Supreme Court held that parol evidence is inadmissible when it seeks to alter rather than explain the contract, as this would contradict the plain meaning of the writing. The justices reasoned that while equity courts might allow flexibility in cases of fraud or trust, as common law judges they must adhere to strict evidentiary rules, distinguishing from state practices lacking equity jurisdiction. They cited precedent from Clarke v. Russel supporting the exclusion of such evidence.
This case concerned whether a writ of error could be brought to the Supreme Court from an interlocutory decree or order issued by a lower court. The Court decided to quash the writ with costs. Under English practice, writs of error are available on interlocutory matters and stay proceedings below, but the governing federal statute permits such writs only in cases of final judgments. The Court therefore concluded that the writ was not authorized here.
