In Lewis Curtis and George Griswold, Trustees of the Appalachicola Land Company v. John and James Innerarity, the Supreme Court was tasked with determining whether a deed from 1825 had been validly executed by two individuals who were not present at its signing. The appellants argued that they had purchased land in Florida from two men named William Houstoun and Thomas Butler King in 1825; however, both men were absent when it was signed. The appellees argued that since neither man was present to sign the deed, it could not be considered legally binding under state law. After considering all evidence presented before them, the Supreme Court determined that although neither party had been physically present for execution of the deed itself, there existed sufficient proof to demonstrate their intention to enter into an agreement regarding said property transaction prior to its signing. As such, they ruled in favor of upholding validity of said deed as per applicable laws governing real estate transactions within Florida's jurisdiction at time of purchase.

In Lewis Curtis and George Griswold, Trustees of the Appalachicola Land Company v. John and James Innerarity, the Supreme Court was asked to decide whether a deed from 1832 conveyed title to certain lands in Florida. The majority opinion held that it did not because there were ambiguities in the language of the deed which could not be resolved without resorting to extrinsic evidence. Justice McLean dissented on this point, arguing that such ambiguities should be interpreted against those who drafted them - namely, Appalacchiola Land Company - since they had knowledge of all relevant facts when drafting it. He further argued that if any ambiguity existed at all then parol evidence should have been admitted as part of trial proceedings so as to resolve it properly before making a decision on title ownership rights. In conclusion he stated his belief that no sufficient proof had been presented by either party for or against their respective claims and thus judgment ought not have been rendered until more conclusive evidence was available for consideration by court members