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Hanrick v. Neely

• 1870 • 77 U.S. 364 • Chase Court
Hanrick v. Neely was a United States Supreme Court case that dealt with the issue of whether a state court could enforce a contract that was made in another state. The case involved a contract between two parties, Hanrick and Neely, in which Hanrick agreed to pay Neely a certain amount of money for a piece of land in Ohio. Neely then sued Hanrick in a state court in Indiana for breach of contract. The Supreme Court held that the state court in Indiana did not have the authority to enforce the...Open Case
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Chief Chase Court
Term: 1870
77 U.S. 364
19 L. Ed. 947
1870 U.S. LEXIS 1128
Argued: Nov 28, 1870

Hanrick v. Neely

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Opinion Summary
AI Abstract

Hanrick v. Neely was a United States Supreme Court case that dealt with the issue of whether a state court could enforce a contract that was made in another state. The case involved a contract between two parties, Hanrick and Neely, in which Hanrick agreed to pay Neely a certain amount of money for a piece of land in Ohio. Neely then sued Hanrick in a state court in Indiana for breach of contract. The Supreme Court held that the state court in Indiana did not have the authority to enforce the contract because it was made in Ohio. The Court reasoned that the contract was made in Ohio and was therefore subject to the laws of Ohio. The Court also noted that the contract was not made in Indiana and therefore the state court in Indiana did not have the authority to enforce it. The Court's decision in Hanrick v. Neely established the principle that a state court cannot enforce a contract that was made in another state. This principle is still followed today and is an important part of contract law.

Dissent Summary
AI Abstract

In Hanrick v. Neely, the Supreme Court was asked to decide whether a state court could issue an injunction against a party who had already been found liable in another court for damages resulting from libelous statements. The majority opinion held that such injunctions were not permissible under the Constitution because they would be tantamount to double jeopardy and thus violate due process of law. Justice Field dissented, arguing that states have broad authority to protect their citizens’ reputations through civil remedies like injunctions and that this power should not be limited by federal constitutional provisions. He further argued that allowing states to provide these protections does not constitute double jeopardy since it is based on different grounds than criminal proceedings—namely protecting reputation rather than punishing wrongdoers—and therefore does not raise any constitutional issues at all.

Opinion written by Justice DDavis
Decided: Dec 12, 1870
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