Clerk v. Russel was a case heard by the United States Supreme Court in 1799. The dispute arose when William Clerk, an executor of a will, sued Thomas Russel for failing to pay debts owed to the estate of John Smith as stipulated in his will. Clerk argued that he had been unable to collect on these debts due to Russel's refusal and sought compensation from him for damages incurred as a result. The court found that while there were no legal grounds upon which Clerk could recover damages from Russel, it did find that he should be compensated for any losses suffered due to his inability to collect on the debt owed by Russet and ordered him paid accordingly. This decision established precedent regarding how executors are able handle cases involving unpaid debts left behind by deceased individuals and set forth guidelines concerning what constitutes reasonable compensation under such circumstances.

In Clerk v. Russell, the Supreme Court was asked to decide whether a state court had authority to issue an injunction preventing a federal officer from performing his duties under the laws of the United States. The majority opinion held that such an injunction could not be issued by a state court as it would interfere with Congress' exclusive power over matters related to foreign affairs and commerce. Justice Chase dissented, arguing that while he agreed with the majority's conclusion on this particular case, he believed that in certain circumstances it may be appropriate for states courts to issue injunctions against federal officers if they are acting beyond their lawful powers or otherwise violating constitutional rights. He argued further that since there is no express provision in either Article III or IV of the Constitution prohibiting such action by state courts, then any attempt at doing so should not be considered unconstitutional unless expressly prohibited by law or precedent.