In Albert Cage and Henry Hays, Executors of Robert H. Cage, Deceased v. Alexander A. Cassidy, William E. Douglass, and William H. Hall, Citizens of the State of Tennessee and Richard Griffith Marshal of the Southern District Mississippi case before the US Supreme Court in 1859 involved a dispute over whether or not an executor could be sued for damages in another state where he was not a resident nor had any property located there at issue in this case was whether or not it violated due process to allow such suits against non-resident executors who were appointed by courts outside that jurisdiction The court held that it did violate due process as allowing such suits would place too great a burden on individuals who may have no connection with the state other than their appointment as executor thus making them liable for damages without being able to defend themselves properly within that jurisdiction

In the dissenting opinion of Albert Cage and Henry Hays, Executors of Robert H. Cage, Deceased v. Alexander A. Cassidy, William E. Douglass, and William H. Hall, Citizens of the State of Tennessee, and Richard Griffith Marshal of the Southern District Mississippi case in 1859 Justice Curtis argued that a state court had no jurisdiction to issue a writ against an executor appointed by another state's court for debts due from his testator before he died or after his death but within its own limits as it was beyond their power to do so under Article IV Section 1 Clause 2 (the full faith & credit clause) which requires states to give full faith & credit to public acts records & judicial proceedings from other states unless there is some special reason why they should not be recognized such as fraud or wanton injustice . He further argued that if this were allowed then each state would have authority over all persons who owe debts in any part thereof regardless where they reside thus making them subject twofold obligations on same debt which would be unjust & oppressive contrary both natural justice common law principles established by our ancestors since time immemorial