In the case of Francis C. Black and James Chapman v. J. W. Zacharie & Co., the plaintiffs in error argued that they had been wrongfully deprived of their property by a fraudulent act committed by defendants, who were acting as agents for them in selling certain cotton bales on commission basis to third parties at New Orleans, Louisiana. The Supreme Court held that although there was evidence indicating fraud or negligence on part of the defendants, it was not sufficient to prove an intentional breach of trust or duty owed to plaintiffs under their contract with defendants; thus, no cause for action existed against them and judgment should be entered in favor of defendant company. Furthermore, since plaintiff's claim did not fall within any recognized legal remedy available at common law or equity court proceedings could not be maintained against defendant company without legislative authority from Congress granting such reliefs which did not exist then either directly or indirectly through state laws applicable to this case scenario

In the case of Francis C. Black and James Chapman v. J. W. Zacharie & Co., Chief Justice Taney delivered a dissenting opinion in which he argued that the Circuit Court had erred in its decision to grant judgment for the defendants, as there was sufficient evidence presented by plaintiffs to support their claim that they were entitled to recover damages from Zacharie & Co.. He further asserted that if it could be shown that any part of the loss sustained by them resulted from negligence on behalf of Zacharie & Co., then they should have been held liable for such losses, regardless of whether or not an express contract existed between them and Black and Chapman at the time when said loss occurred. In conclusion, Chief Justice Taney concluded his dissent with a statement affirming his belief that “the law is clear” regarding this matter; namely, “that where one party has received benefit from another under circumstances importing some obligation upon him either expressed or implied…he ought not to be permitted afterwards to deny it without making compensation."