Noel Jourdan and Joseph Landry, plaintiffs in error, brought a case against Thomas Barrett et al. The dispute was over the ownership of certain land located in Louisiana. Jourdan and Landry argued that they had acquired title to the land through a Spanish grant issued by Governor Miro in 1788. However, Barrett et al claimed that their own title derived from an act passed by Congress which authorized them to purchase it from the United States government. The Supreme Court held that although Congress could not pass laws retroactively affecting vested rights under state law, this did not apply here because no such right existed at the time of passage of the Act; therefore, it was validly applicable to this situation and thus granted possession of the property to Barrett et al.

In the case of Noel Jourdan and Joseph Landry v. Thomas Barrett et al., the dissenting opinion argued that Louisiana had a right to pass laws which regulated slavery, as long as they did not conflict with any federal law or treaty. The majority opinion held that such laws were unconstitutional because they violated the Fifth Amendment's Due Process Clause, which states that no person shall be deprived of life, liberty or property without due process of law. However, in this case it was argued by Justice Catron in his dissent that since there was no federal statute prohibiting Louisiana from passing its own regulations on slavery then these regulations should stand and be enforced accordingly. Furthermore he stated that Congress had never passed any legislation regarding slavery so therefore it could not interfere with state regulation on this matter either. He concluded by saying if Congress wanted to regulate slavery then it should do so through an act of Congress rather than trying to invalidate state laws already in place concerning this issue.