In the Clay v. Field case of 1890, the U.S Supreme Court was tasked with determining whether a California law that allowed married women to sell their separate property without their husband's consent was constitutional. The court ruled in favor of Mrs. Clay, upholding her right to sell her property independently under California state law and rejecting Mr. Field’s claim on it as unlawful interference. The case revolved around an agreement between Mrs. Clay and Mr.Field where she sold him land for $5,000 but later refused to transfer the title deed claiming undue influence by her husband who had financial interests with Mr.Field at that time. Mr.Field sued Mrs.Clay arguing that he should be given possession of the land or refunded his money since she willingly entered into contract despite any alleged pressure from her spouse. However, Justice Samuel Miller delivered an opinion stating that if a wife is coerced by her husband into selling property against her will then such contracts are voidable at wife's discretion even after receiving payment unless third party rights have intervened making rescission inequitable.

In the dissenting opinion for Clay v. Field, it was argued that the court majority had erred in its interpretation of the law and application to this case. The dissenting justices believed that Mr. Clay should not be held liable for his wife's debts incurred before their marriage because he did not explicitly assume responsibility for them upon marrying her, as required by California law at that time. They also disagreed with the majority's view on community property laws, arguing these laws were intended to protect a spouse from being burdened with premarital debt unless they willingly assumed such obligations. Furthermore, they contended that Mrs. Clay’s creditors should have pursued legal action against her separately rather than involving Mr.Clay who had no part in contracting those debts.