This Supreme Court case involved Clement Woodward, the plaintiff in error, and James Brown and Sarah Jane, his wife, defendants in error. The dispute was over a tract of land located in Alabama that had been sold to Woodward by Brown. At issue was whether or not the deed given to Woodward by Brown conveyed title to the property as it did not contain any words of conveyance. The court found that although there were no explicit words of conveyance used on the deed itself, other evidence presented showed that an agreement between both parties existed which indicated an intent for title transfer from Brown to Woodward. Furthermore, since possession had already been transferred at this point with payment made for said property according to their agreement; it could be inferred that a valid contract existed between them which provided sufficient legal grounds for conveying title from one party (Brown) to another (Woodward). Thusly, the court ruled in favor of Woodward and held him entitled as owner of said land.

In this case, the plaintiff argued that he had a valid lien on certain property owned by the defendants. The Supreme Court of Georgia found in favor of the defendants and held that no such lien existed. In dissent, Justice Lumpkin argued that there was sufficient evidence to support a finding of a valid lien in favor of the plaintiff. He noted that while it is true that liens must be created with specific intent, here there were facts which showed an agreement between parties for payment and delivery as security for debt owed by one party to another. Furthermore, he pointed out how these facts could have been used to infer an intention from both sides to create such a lien even if not explicitly stated or agreed upon at any point during their dealings with each other. Ultimately, Justice Lumpkin concluded his opinion by stating his belief that under these circumstances it would be unjust and inequitable for the court not to recognize some form of legal protection over what was due from one party to another based on their prior agreements regarding payment and delivery as security for debt owed.