In the case of Henry Toland v. Horatio Sprague, Toland brought a suit against Sprague for damages resulting from an alleged breach of contract. The Supreme Court found that there was no evidence to support the claim and ruled in favor of Sprague. The court held that even if it were assumed that a contract had been made between the parties, there was no proof as to its terms or conditions and therefore could not be enforced by law. Furthermore, any agreement which might have existed between them did not constitute sufficient consideration for either party's promise to perform their respective obligations under it. As such, the court concluded that Toland had failed to prove his case and dismissed his complaint with costs awarded against him

In the case of Henry Toland v. Horatio Sprague, the Supreme Court was tasked with deciding whether a state court had jurisdiction to hear a suit brought by an alien against another citizen of that same state. The majority opinion held that it did not have such authority as aliens were not considered citizens and thus could not bring suits in state courts. However, Justice McLean dissented from this ruling arguing that states should be able to decide for themselves who has access to their courts and what types of cases they can adjudicate within those courts. He argued further that there is no constitutional provision which prohibits aliens from bringing suits in state court or otherwise denies them access to justice on equal terms with other litigants before the law. Therefore, he concluded, it would be wrong for the federal government to interfere with this right granted by individual states through judicial fiat rather than legislative action or amendment of the Constitution itself.