In W. and H. Massingill v A.C Downs, the Supreme Court of the United States heard a case concerning an appeal from a decision by the Circuit Court for the District of Columbia in favor of A.C Downs as claimant to certain property located in Washington County, Maryland that had been seized by W and H Massingill under execution issued out of said court against one John Bowers who was indebted to them on two notes given for money lent him at different times prior to 1845 when he conveyed all his real estate situated in said county to defendant Downes without consideration or valuable security therefor with intent thereby fraudulently hinder delay and defraud creditors like plaintiffs herein The Supreme Court held that although it is true that fraudulent conveyances are voidable only at equity yet if they be made with such circumstances as will amount either directly or indirectly to actual fraud upon creditors then courts of law may take cognizance thereof; thus affirming the lower court's ruling in favor of Defendant Downes

In the case of W. and H. Massingill v A.C Downs, the dissenting opinion was that a contract between two parties should be upheld even if it is not in writing or signed by both parties as long as there is sufficient evidence to prove its existence and validity. The majority opinion held that verbal contracts were invalid unless they could be proven with clear and convincing evidence, which would have been difficult for either party to do since no written record existed of their agreement at the time of trial. Justice Catron argued that this standard was too high given how common verbal agreements are in everyday life; he believed such an interpretation would lead to injustice when one party had acted on an oral promise only for it later to be denied due to lack of proof beyond a reasonable doubt. He also noted that requiring strict proof might encourage fraudulence from those who wished to take advantage of others without having any legal recourse against them afterwards because they had failed meet the burden set forth by law