In Thomas Leggett, Junior, Samuel Smith and Smith Lawrence v. Benjamin G. Humphreys, the appellants argued that a deed of trust executed by them to Humphreys was invalid because it had not been properly acknowledged before an officer authorized to take acknowledgments in Mississippi. The Supreme Court held that although the deed of trust was not acknowledged as required by state law, it could still be enforced under federal common law since there were no other defects in its execution or delivery. Furthermore, the court noted that even if there had been some defect in acknowledgment due to lack of authority on behalf of the officer taking it, this would have only affected its validity under state law but would not necessarily render it void for all purposes under federal common law.

In Thomas Leggett, Junior, Samuel Smith and Smith Lawrence v. Benjamin G. Humphreys, the Supreme Court was tasked with deciding whether a contract between two parties could be enforced when it had been made without consideration or mutuality of obligation. The majority opinion held that such contracts were not enforceable because they lacked consideration and mutuality of obligation; however Justice Curtis dissented from this ruling on the basis that there was sufficient evidence to suggest that both parties intended for their agreement to be binding even though it did not meet all legal requirements for an enforceable contract. He argued that since one party had already performed his part of the agreement in good faith before any dispute arose over its validity, he should still have recourse under law if necessary to receive compensation for his efforts despite any technical deficiencies in the original contract itself.