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M'intire v. Wood

1813 • 11 U.S. 504 • Marshall Court
M'Intire v. Wood was a case heard by the United States Supreme Court in 1813. The dispute arose when M’Intire, an American citizen, sued Wood for breach of contract after he sold her goods to another party without her consent or knowledge. At issue before the court was whether state courts had jurisdiction over contracts made between citizens of different states and if so, what law should be applied to resolve such disputes? In its decision, the court held that state courts did have...Open Case
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Chief Marshall Court
Term: 1813
11 U.S. 504
3 L. Ed. 420
1813 U.S. LEXIS 448

M'intire v. Wood

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Opinion Summary
AI Abstract

M'Intire v. Wood was a case heard by the United States Supreme Court in 1813. The dispute arose when M’Intire, an American citizen, sued Wood for breach of contract after he sold her goods to another party without her consent or knowledge. At issue before the court was whether state courts had jurisdiction over contracts made between citizens of different states and if so, what law should be applied to resolve such disputes? In its decision, the court held that state courts did have jurisdiction over such cases but that they must apply federal common law rather than local laws in order to ensure uniformity among all states. Furthermore, it established precedent for future cases involving interstate commerce and contractual disputes between citizens of different states.

Dissent Summary
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In M'Intire v. Wood, the Supreme Court was asked to decide whether a contract between two parties that had been made in Virginia and then moved to New York could be enforced under New York law. The majority of the court held that it could not because there was no evidence that either party intended for the contract to be governed by New York law when they entered into it. Justice Johnson dissented from this opinion, arguing that contracts should generally be enforceable regardless of where they were formed or which state's laws applied at the time of formation. He argued further that if one party wanted to take advantage of another’s ignorance regarding applicable laws, then such an act would constitute fraud and thus render any agreement voidable at best - but certainly not unenforceable as a matter of public policy.

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