Edward H. McCabe brought a case against Lloyd D. Worthington to the Supreme Court of the United States in 1853. The dispute was over an agreement between them that stated if McCabe paid off certain debts for Worthington, he would be entitled to receive one-third of all profits from any land sales made by Worthington within two years after paying off those debts. After fulfilling his end of the bargain, McCabe sued when he did not receive his promised share from some land sales made by Worthinton during this time period and requested damages as compensation for breach of contract. The court found in favor of Worthinton on grounds that there had been no consideration given for their agreement because it was based solely on past services rendered rather than future ones, which is required under common law contracts at that time and still today in many jurisdictions.

In the case of Edward H. McCabe v. Lloyd D. Worthington, the Supreme Court was tasked with determining whether a contract between two parties could be enforced if it had been made under duress and coercion by one party against another. The majority opinion held that such contracts were not enforceable, but Justice Daniel dissented from this ruling on the grounds that there was no evidence to suggest that either party had acted in bad faith or fraudulently when entering into their agreement. He argued further that even if one party did act coercively, it would still be possible for them to recover damages for any losses they suffered as a result of being forced into an unfavorable deal; however, he ultimately concluded that since neither side presented sufficient proof of wrongdoing or malice during negotiations, both should have their rights respected and upheld according to law regardless of how they came about making their contract in the first place.