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Hodges v. Easton

• 1882 • 106 U.S. 408 • Waite Court
Hodges v. Easton 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 violation of a state statute. The case involved a contract between two parties, Easton and Hodges, in which Easton agreed to pay Hodges a certain amount of money in exchange for Hodges' services. The contract was made in violation of a state statute that prohibited such contracts. The Supreme Court held that the state court could not enforce the...Open Case
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Chief Waite Court
Term: 1882
Docket: 92
106 U.S. 408
1 S. Ct. 307
27 L. Ed. 169
1882 U.S. LEXIS 1554
Argued: Nov 17, 1882

Hodges v. Easton

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Opinion Summary
AI Abstract

Hodges v. Easton 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 violation of a state statute. The case involved a contract between two parties, Easton and Hodges, in which Easton agreed to pay Hodges a certain amount of money in exchange for Hodges' services. The contract was made in violation of a state statute that prohibited such contracts. The Supreme Court held that the state court could not enforce the contract because it was made in violation of the state statute. The Court reasoned that the state statute was a valid exercise of the state's police power and that the state had the right to protect its citizens from contracts that were made in violation of the law. The Court also noted that the state had the right to protect its citizens from contracts that were made in bad faith or with the intent to defraud. The Court's decision in Hodges v. Easton established that state courts could not enforce contracts that were made in violation of state statutes. This decision has been cited in numerous cases since then and has been used to support the idea that state courts should not enforce contracts that are made in violation of the law.

Dissent Summary
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Justice Field delivered the dissenting opinion in Hodges v. Easton, arguing that the majority's decision was incorrect and should be reversed. He argued that a state statute could not override an act of Congress, as it would violate Article VI of the Constitution which states that laws passed by Congress are "the supreme Law of the Land." Furthermore, he noted that while there may have been some ambiguity in how to interpret certain parts of both statutes at issue in this case, such ambiguities should be resolved against those who created them - namely, the legislature - rather than against individuals like Mr. Hodges who had no control over their creation or interpretation. Finally, Justice Field concluded his dissent by noting that if one were to accept the majority's reasoning then any state law could supersede federal legislation whenever they conflicted with each other; something he believed was clearly contrary to what is laid out in Article VI and thus must be rejected outright.

Opinion written by Justice JHarlan(1)
Decided: Dec 04, 1882
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