Edmund P. Gaines and Mira Clarke, late Whitney, brought a case against Richard Relf, Beverly Chew and others to the Supreme Court in 1841. The complainants argued that they had been wrongfully deprived of their rights as citizens of the United States by being denied access to certain lands granted them by Congress in 1838. They claimed that these defendants had unlawfully taken possession of said lands without any legal authority or right whatsoever. The Supreme Court found for the plaintiffs and ordered that all parties involved be enjoined from interfering with the complainants' rights to possess said land until further order from court. Furthermore, it was determined that if any damages were incurred due to this interference then those responsible would be held liable for such damages accordingly.

In the case of Edmund P. Gaines and Mira Clarke, late Whitney v. Richard Relf, Beverly Chew and others, the Supreme Court was asked to decide whether a deed from one party to another was valid when it had been signed by an attorney-in-fact who did not have power of attorney for that purpose. The majority opinion held that the deed was invalid because it lacked sufficient proof of authority in order for it to be binding on both parties. However, Justice McLean dissented from this decision arguing that there were other facts which should be considered before declaring the deed invalid such as evidence showing knowledge or acquiescence by all parties involved in its execution and delivery. He argued further that if these facts could be established then they would provide sufficient proof of authority even without a formal power of attorney document being present at time of signing.