Cogswell v. Fordyce was a Supreme Court case that was decided in 1883. The case involved a dispute between two parties over a contract for the sale of a steamboat. The plaintiff, Cogswell, had contracted with the defendant, Fordyce, to purchase a steamboat for $2,000. Cogswell paid the full amount, but Fordyce refused to deliver the boat. Cogswell then sued Fordyce for breach of contract. The Supreme Court held that the contract was valid and enforceable. The Court found that the contract was supported by consideration, meaning that both parties had given something of value in exchange for the other's promise. The Court also found that the contract was not voidable due to any lack of capacity or fraud. The Court ultimately held that Fordyce was liable for breach of contract and ordered him to pay Cogswell the full amount of $2,000 plus interest. The Court also held that Cogswell was entitled to damages for the delay in delivery of the steamboat. This case established the principle that a contract is binding and enforceable if it is supported by consideration and is not voidable due to any lack of capacity or fraud.

In the Supreme Court case of Cogswell v. Fordyce, Justice Field delivered a dissenting opinion in which he argued that the majority had misinterpreted an earlier decision and failed to consider relevant facts. He noted that while it was true that under certain circumstances, a contract could be implied from conduct alone, this was not one of those cases. In his view, there were no facts present to support such an implication; rather than being based on mutual understanding or agreement between parties as required for a valid contract formation, any promises made by either party were too vague and uncertain to constitute consideration sufficient for contractual obligations. Furthermore, even if some sort of agreement had been reached between the parties at issue here – something which Justice Field felt was highly unlikely – it would have still been invalid due to its lack of specificity regarding terms and conditions necessary for enforcement. As such, he concluded that the lower court’s ruling should stand: Cogswell did not owe Fordyce anything beyond what she already paid him in rent prior to their dispute over ownership rights related thereto