Andrews v. Cone is a United States Supreme Court case that was decided in 1887. The case involved a dispute between two parties over a contract for the sale of a steamboat. The plaintiff, Andrews, had contracted to purchase the steamboat from the defendant, Cone. However, Cone refused to deliver the boat, claiming that the contract was invalid because it had not been signed by both parties. The Supreme Court held that the contract was valid and enforceable. The Court reasoned that the contract was binding because it had been signed by Andrews and accepted by Cone. The Court also noted that the contract had been partially performed, as Andrews had already paid a portion of the purchase price. Therefore, the Court held that Cone was obligated to deliver the steamboat to Andrews.

Justice Field delivered the dissenting opinion in Andrews v. Cone, arguing that the majority had misapplied the law of contracts to reach its conclusion. He argued that a contract is not formed when one party makes an offer and another party expresses their willingness to accept it; rather, he asserted that a contract requires both parties to agree on all material terms before any obligations can be enforced. In this case, Justice Field argued that there was no agreement between Andrews and Cone as they never agreed upon how much money would be paid for the land or when payment would be due. Therefore, he concluded that no valid contract existed between them and thus Cone could not enforce his claim against Andrews for breach of contract.