In the Matter of Nicholas Lucien Metzger, a case heard before the United States Supreme Court in 1847, concerned whether or not a minor could be held liable for debts incurred while under age. The court found that minors were not responsible for contracts made prior to their majority and thus could not be held liable for such debts. This ruling was based on common law principles which stated that minors lacked capacity to enter into binding agreements until they reached adulthood. Furthermore, it was argued that allowing minors to incur debt would lead to exploitation by creditors who may take advantage of young people's lack of experience and knowledge when entering into financial transactions. As such, this decision provided protection from creditors seeking repayment from those too young to understand the implications of their actions at the time they entered into an agreement with them.

In the Matter of Nicholas Lucien Metzger, the Supreme Court was asked to decide whether a state court had jurisdiction over a case involving an individual who was born in France and later became a naturalized citizen of Louisiana. The majority opinion held that the state court did have jurisdiction because it found that Metzger's citizenship status at birth did not affect his current legal status as a citizen of Louisiana. However, Justice McLean dissented from this ruling on two grounds: firstly, he argued that under international law, individuals are subject to their country of origin until they renounce their allegiance; secondly, he maintained that since Metzger had never taken any action to become an American citizen or renounce his French citizenship prior to being sued in Louisiana courts, those courts lacked jurisdiction over him. He concluded by asserting that if states were allowed such broad powers over foreign-born citizens without them taking any affirmative steps towards becoming part of America then it would be contrary to both public policy and justice.