In Doe, Ex Dem. Governour's Heirs v. Robertson and Others, the Supreme Court of the United States was asked to decide whether a deed given by an individual in Virginia prior to its admission into the Union was valid under federal law. The court held that it was not because at the time of its execution, there were no laws in place which would have made such a deed legally binding. Furthermore, since Virginia had yet to be admitted as a state when this transaction occurred, any contract or agreement entered into between two parties within her boundaries could not be enforced according to federal law until she became part of the union. This decision established that contracts executed before statehood are invalid unless they can be validated through subsequent legislation enacted after admission into the Union has been granted.

In Doe, ex dem. Governeur's Heirs v. Robertson and Others, the Supreme Court was asked to decide whether a deed of land from an individual who had died intestate could be validly executed by his heirs without probate proceedings being conducted first. The majority opinion held that such a deed was invalid because it violated the state law requiring all estates to go through probate before any transfer of title can take place. In dissent, Justice Story argued that this interpretation would lead to absurd results since it would mean that if someone dies intestate with no known heirs then their property will remain unclaimed forever due to lack of anyone able to execute a valid conveyance on behalf of the deceased person’s estate. Furthermore, he noted that there were many cases in which individuals have been allowed by courts in other states and territories where similar laws existed for them to inherit property without going through formal probate proceedings first; thus allowing these same rights should not be seen as contrary or unreasonable under existing legal precedent either at common law or within equity jurisprudence more broadly speaking