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Irvine v. Dunham is a United States Supreme Court case that was decided in 1884. The case involved a dispute between two parties over the ownership of a piece of land in the state of Ohio. The plaintiff, Irvine, claimed that he had purchased the land from the defendant, Dunham, in 1867. Dunham, however, argued that the sale was invalid because he had not received full payment for the land. The Supreme Court ultimately sided with Irvine, ruling that the sale was valid and that Irvine was the rightful owner of the land. The Court reasoned that Dunham had accepted partial payment for the land and had not taken any action to reclaim it for over fifteen years. The Court also noted that Dunham had not provided any evidence that he had ever attempted to reclaim the land. As a result, the Court held that Irvine was the rightful owner of the land and that Dunham had no legal claim to it.
Justice Field delivered the dissenting opinion in Irvine v. Dunham, arguing that the majority's decision was wrongfully based on a misinterpretation of California law. He argued that under California law, an executor or administrator could not be held liable for debts incurred by their decedent unless they had personally authorized them to do so; this did not apply to debtors who were already deceased at the time of authorization. Furthermore, he noted that even if such liability existed under state law, it would still be subject to federal bankruptcy laws which prohibited creditors from collecting more than what was owed by a debtor’s estate after death. Therefore, Justice Field concluded that there should have been no recovery against Mr. Irvine as he had never given any personal authority for his father’s debts and those debts were discharged upon his father's death according to federal bankruptcy laws.