In Daniel Green's Administratrix v. Fletcher Creighton, the Supreme Court of the United States was asked to decide whether a deed executed by Jonathan McCaleb in 1845 and delivered to his son-in-law, Fletcher Creighton, could be set aside as fraudulent. The court held that it could not because there was no evidence of fraud or undue influence on the part of either party at the time when it was made. Furthermore, even if such evidence had been presented, it would have been too late for relief since more than ten years had passed since its execution and delivery. The court concluded that under these circumstances a deed is valid unless proven otherwise within 10 years from its date; after this period has elapsed any claim based upon fraud must fail due to laches (unreasonable delay).

In Daniel Green's Administratrix v. Fletcher Creighton, the Supreme Court was tasked with determining whether a deed of trust executed by Jonathan McCaleb in 1843 was valid and binding on his estate after his death in 1848. The majority opinion held that the deed of trust was not valid because it had not been recorded before McCaleb's death as required by state law. However, Justice Grier dissented from this decision, arguing that although recording is generally necessary to make a conveyance effective against third parties, it should be unnecessary when there are no third parties involved or affected by the transaction at issue here. He further argued that since McCaleb had already taken possession of the property conveyed under the deed prior to his death and since he did so without any objection from anyone else claiming an interest in said property during those five years between execution and death, then such possession should be sufficient evidence for establishing title to said property even if there has been no recordation made thereof according to state law requirements.