John H. Lewis, appellant, brought a case against Sarah Darling in the Supreme Court of the United States. The dispute was over whether or not Darling had to pay for damages caused by her cattle that were allowed to roam freely on Lewis’ land and destroyed his crops. In order for Lewis to be able to recover any compensation from Darling he needed proof that she knew about her cattle being on his property and did nothing about it; however, there was no evidence presented at trial showing this knowledge. Therefore, the court ruled in favor of Sarah Darling as John H. Lewis failed to prove that she had been negligent with regard to her animals roaming onto his land without permission or supervision resulting in damage done thereto.

In the case of John H. Lewis v Sarah Darling, the Supreme Court was asked to decide whether a deed given by Darling to Lewis for land in California was valid. The majority opinion held that it was not, as there were no witnesses present at the time of execution and thus it did not meet the requirements set forth in California's Statute of Frauds. However, Justice Curtis dissented from this decision on two grounds: firstly, he argued that since both parties had already been living on and using the land prior to executing any written agreement they should be considered tenants-in-common with an implied right of survivorship; secondly, he argued that even if such an implied tenancy could not be established then Darling would still have conveyed her interest in good faith when she gave Lewis possession without requiring him to sign anything or pay money for it. In either case Curtis concluded that equity demanded recognition of some kind of title vested in Lewis which should have been upheld by the court instead being dismissed out-of-hand due its lack formalities required under state law.