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Harrell v. Beall, Assignee was a case heard by the United States Supreme Court in 1873. The case involved a dispute between two parties over a promissory note. The plaintiff, Harrell, had given the defendant, Beall, a promissory note for $1,000. Beall then assigned the note to another party, who then sued Harrell for payment. Harrell argued that the assignment was invalid because it was not in writing, as required by the Statute of Frauds. The Supreme Court held that the assignment was invalid because it was not in writing. The Court reasoned that the Statute of Frauds required that all assignments of promissory notes be in writing in order to be valid. The Court also noted that the Statute of Frauds was intended to protect parties from fraud and that the assignment in this case did not meet the requirements of the Statute. The Court's decision in Harrell v. Beall, Assignee established that all assignments of promissory notes must be in writing in order to be valid. This decision has been cited in numerous subsequent cases and is still good law today.
Justice Field delivered the dissenting opinion in Harrell v. Beall, Assignee. He argued that the majority had incorrectly interpreted a provision of Maryland's insolvency law which allowed creditors to collect on debts owed by an insolvent debtor from any assets held by them at the time of their bankruptcy filing. The majority had ruled that this provision did not apply when a creditor was holding property as security for debt repayment and thus could not be used to satisfy such debts. Justice Field disagreed with this interpretation, arguing instead that it should be applied regardless of whether or not the creditor was holding property as security for debt repayment; he believed that if Congress intended otherwise they would have included language specifying so in the statute itself. Furthermore, he noted how allowing creditors to use secured assets to pay off debts would benefit both parties involved: it would allow creditors who were unable to recover all their money due to insufficient funds available from unsecured sources access more funds while also providing some relief for debtors who may otherwise face harsh consequences due solely because they are unable repay what is owed in full under current circumstances.