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John Howland, Samuel Meeker, John Chadwick and Oliver S. Halstead Jr. were the claimants of the Barque Griffin, her tackle and other items (the appellants) in a case against John Greenway and George S. Dickson (the libellants). The Supreme Court was asked to decide whether or not certain goods that had been seized by the United States Marshal should be returned to their rightful owners - namely those who owned them prior to seizure. The court found that since there was no proof of ownership presented at trial, it could not determine with certainty who owned these goods before they were taken into custody by the marshal; therefore they ruled in favor of neither party but instead ordered for an accounting between all parties involved so as to ascertain which person(s) rightfully own said property.
In the dissenting opinion of this case, Justice Curtis argued that the libellants had not proven their claim to a lien on the barque Griffin. He noted that while they had provided evidence of an agreement between them and Captain Howland for repairs to be made to the vessel, there was no proof that any money or other consideration had been paid in exchange for those services. Furthermore, he stated that even if such payment were established, it would still need to be shown how much was owed before a lien could be granted. As such, Justice Curtis concluded that since neither party presented sufficient evidence regarding these matters during trial proceedings, it would have been inappropriate for the court to grant a lien in favor of either side.