John Lloyd, plaintiff in error, brought a case against Charles Scott, bailiff of William S. Moore. The dispute arose when John Lloyd was arrested and taken into custody by the defendant for failing to appear as a witness at court proceedings. John argued that he had not been served with an official summons prior to his arrest and thus could not be held accountable for his absence from the trial. He further claimed that even if he had received notice of the hearing, it would have been impossible for him to attend due to financial hardship caused by illness in his family which prevented him from leaving home or hiring someone else to go on his behalf. The Supreme Court ultimately sided with John Lloyd and ruled that since there was no proof of service presented during the trial nor any other evidence indicating knowledge of the summons on part of Mr.Lloyd; therefore it was unlawful for Charles Scott (bailiff)to take him into custody without proper cause or authority under law .

In John Lloyd, Plaintiff in Error vs. Charles Scott, Bailiff of William S. Moore, Defendant (1830), the dissenting opinion was that the plaintiff should have been allowed to bring his action against the defendant for false imprisonment and damages as a result of an arrest made without legal authority or process from a court of competent jurisdiction. The majority had held that since no actual physical force was used by the defendant when making the arrest, there could be no cause of action because it did not constitute false imprisonment under common law principles at that time. However, Justice Baldwin argued in dissent that even if there were no physical force involved with this particular case, any wrongful detention is sufficient to support an action for false imprisonment regardless whether it is done through threats or other means such as verbal commands which can still amount to duress and coercion on behalf of those being detained unlawfully. He further noted how allowing such actions would help protect citizens’ rights from arbitrary arrests and detentions by public officers who may act beyond their lawful authority without consequence otherwise.