Francis Martin, administrator of Dennis T. Donovan, deceased, brought a case against Christian Imhsen in the Supreme Court. The dispute was over a promissory note that had been signed by Donovan and payable to Imhsen for $1,000 plus interest. Martin argued that the note should be voided because it had not been properly witnessed as required by law at the time of its signing. However, Imhsen countered with evidence showing that he had paid consideration for the note prior to its execution and delivery which made it valid under common law principles even without witnesses present at signing. After considering both sides' arguments carefully, the court ultimately ruled in favor of Imhsen on grounds that his payment constituted sufficient consideration to make up for any lack of proper witnessing when executing the instrument.

In the case of Francis Martin, Administrator of Dennis T. Donovan, Deceased v. Christian Imhsen, Justice John Catron delivered a dissenting opinion in which he argued that the court should not have reversed the decision made by the lower court and instead should have affirmed it. He believed that there was sufficient evidence to support the lower court's ruling that Imhsen had breached his contract with Donovan and thus owed damages for breach of contract as well as interest on those damages from when they were due until paid in full. Furthermore, Catron disagreed with his colleagues' interpretation of Tennessee law regarding contracts between merchants; he felt their interpretation was too narrow and did not take into account all relevant factors such as custom or usage among merchants at that time period. In conclusion, Justice Catron argued against reversing the judgment rendered by the lower court because there was ample evidence to support its ruling and because he disagreed with how his colleagues interpreted Tennessee law concerning merchant contracts at this time period.