In Stephen W. Doss and Stewart Newell v. William Tyack and Lindley Murray, the appellants argued that a deed of trust was invalid because it had been made without consideration or mutual agreement between the parties involved in the transaction. The Supreme Court ruled against them, finding that although there was no evidence of consideration for the deed, it did not necessarily make it invalid as long as both parties agreed to its terms. Furthermore, they found that since Tyack and Murray had accepted possession of land under this deed with full knowledge of its contents, their acceptance constituted an implied contract which rendered any lack of consideration moot. Ultimately then, even though there was no proof that either party received something in exchange for entering into this agreement - such as money or goods - their consent to abide by its conditions still held legal weight in court.

In Stephen W. Doss and Stewart Newell v. William Tyack and Lindley Murray, the Supreme Court was asked to decide whether a contract between two parties could be enforced if it had been made in violation of an existing state law. The majority opinion held that the contract was not enforceable because it violated the state law, but Justice McLean dissented from this decision on several grounds. He argued that since there were no penalties associated with violating the particular statute in question, then its purpose must have been merely to regulate commerce rather than prohibit contracts altogether; therefore, he concluded that any contracts made in violation of such a statute should still be valid and binding upon both parties involved. Furthermore, he reasoned that allowing courts to invalidate contracts based on violations of statutes would lead to uncertainty as well as encourage people to break their agreements without consequence or fear of punishment for doing so - something which would ultimately undermine public confidence in contractual obligations more generally.