Andrews v. Hovey was a United States Supreme Court case that addressed the issue of whether a contract between two parties was valid. The case involved a contract between the plaintiff, Andrews, and the defendant, Hovey, in which Andrews agreed to pay Hovey a certain amount of money in exchange for Hovey's promise to convey certain real estate to Andrews. The Supreme Court held that the contract was valid and enforceable. The Court reasoned that the contract was valid because it was supported by consideration, which is an essential element of a valid contract. The Court found that the consideration was sufficient because Andrews had agreed to pay a certain amount of money in exchange for Hovey's promise to convey the real estate. The Court also found that the contract was not void for lack of mutuality of obligation, as Hovey had promised to convey the real estate and Andrews had promised to pay the money. The Court also held that the contract was not void for lack of consideration, as the consideration was sufficient and the parties had agreed to the terms of the contract. The Court also found that the contract was not void for lack of capacity, as both parties had the capacity to enter into the contract. In conclusion, the Supreme Court held that the contract between Andrews and Hovey was valid and enforceable. The Court found that the contract was supported by consideration, was not void for lack of mutuality of obligation, was not void for lack of consideration, and was not void for lack of capacity.

Justice Field delivered the dissenting opinion in Andrews v. Hovey, arguing that the majority's decision was wrongfully based on a misapplication of state law. He argued that the court should have applied federal common law to this case because it involved an issue of national importance - namely, whether or not a contract between two citizens from different states could be enforced by one party against another in a federal court. Justice Field further argued that even if state law did apply, then under California's laws at the time (which were applicable to this case), there was no legal basis for denying enforcement of contracts made out-of-state and brought into California for performance. In conclusion, he stated his belief that enforcing such contracts would promote commerce among all states and benefit both parties involved in interstate transactions; thus, he concluded with his dissent from the majority opinion which denied enforcement of such contracts as being contrary to public policy.