In James Greenleaf's Lessee Plaintiff in Error vs. James Birth, Defendant in Error, the Supreme Court was asked to decide whether a deed of trust executed by a mortgagor and his wife could be enforced against them after they had conveyed their interest in the property to another party. The court held that while the deed of trust was valid when it was created, it did not bind either spouse once they had transferred their interests to someone else. This decision established an important precedent for future cases involving deeds of trust and marital rights over real estate.

In James Greenleaf's Lessee Plaintiff in Error vs. James Birth, Defendant in Error, the Supreme Court was asked to decide whether a tenant had the right to remove improvements made on leased land after their lease expired. The majority opinion held that tenants did not have such rights and that any improvements they made became part of the property upon expiration of their lease. However, Justice Story dissented from this decision and argued that it would be unjust for tenants who had improved leased lands with no expectation or agreement that those improvements would become permanent fixtures of the property to lose them without compensation when their leases expired. He further noted how common it was for landlords and tenants alike to expect some form of compensation if either party wished to keep any improvement made during tenancy; thus he concluded that denying these rights could lead to great hardship for both parties involved.