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In the case of Daniel H. Lownsdale and Others v Josiah L. Parrish, appellants sought to recover damages from Parrish for a breach of contract involving the sale of land in Oregon Territory. The Supreme Court held that when an agreement is made between two parties with respect to real estate located in a territory not yet admitted into the Union, it must be considered as if it were made within such state or territory after its admission into the Union; thus, any rights acquired under such agreements are subject to all laws enacted by Congress applicable thereto after its admission into the Union. Furthermore, since no action could have been maintained at law upon this contract before Oregon's admission as a State due to lack of jurisdiction over non-state territories, equity was available only through chancery courts established by Congress pursuant to their power granted by Article IV Section 3 Clause 2 of Constitution which allowed them exclusive original jurisdiction over cases arising out of contracts concerning lands situated in different states or territories prior to their respective admissions as States. Thus, because there was no court having general common law jurisdiction until Oregon became a state and therefore no remedy at law existed for breach thereof prior thereto; consequently appellants had right seek relief solely through equity proceedings instituted thereafter according tot he rules prescribed by Congress governing same
In the case of Daniel H. Lownsdale and Others v. Josiah L. Parrish, the Supreme Court was asked to decide whether a deed given by an individual in Oregon Territory prior to its admission into statehood could be enforced after it became a state. The majority opinion held that such deeds were valid and enforceable under the laws of Oregon upon its admission as a state, but Justice Grier dissented from this decision on two grounds: firstly, he argued that Congress had not authorized any court in Oregon Territory to pass judgment on matters relating to real estate; secondly, he noted that there was no evidence presented at trial which showed that either party intended for their agreement regarding land ownership rights to remain binding after Oregon's transition from territory status into full-fledged statehood. Therefore, Justice Grier concluded that since neither party had expressed intent for their contract concerning land rights to survive beyond territorial status, it should not be considered legally binding once Oregon officially became a part of the United States as one of its states.