Mitchell v. Burlington was a United States Supreme Court case that was decided in 1866. The case involved a dispute between two parties over the ownership of a piece of land in the state of Iowa. The plaintiff, Mitchell, claimed that he had purchased the land from the defendant, Burlington, in 1859. Burlington, however, argued that the sale was invalid because the deed was not properly recorded. The Supreme Court ultimately sided with Mitchell, ruling that the deed was valid and that Mitchell was the rightful owner of the land. The Court held that the deed was valid because it had been delivered to Mitchell and accepted by him, and that the failure to record the deed did not invalidate the sale. The Court also held that the statute of limitations had not expired, and that Mitchell was therefore entitled to the land. The decision in Mitchell v. Burlington established that a deed is valid even if it is not recorded, as long as it has been delivered and accepted by the purchaser. This ruling has been cited in numerous cases since then, and has become an important part of property law in the United States.

In Mitchell v. Burlington, the Supreme Court was tasked with deciding whether a contract between two parties for the sale of land in Iowa could be enforced by an action brought in Illinois, where one of the parties resided. The majority opinion held that it could not; however, Justice Field dissented from this decision and argued that there should be no distinction made between contracts entered into within a state and those entered into outside its borders when determining their enforceability. He reasoned that if such distinctions were to exist then interstate commerce would suffer greatly as individuals would have little incentive to enter into business transactions across state lines due to uncertainty about enforcement rights. Furthermore, he noted that Congress had already passed legislation allowing citizens of different states to sue each other in federal courts regardless of where they reside or what type of contract is involved and thus any further restrictions on enforcing contracts across state lines should not come from judicial interpretation but rather through congressional action alone.