In the case of Dickerson B. Morehouse v. William A. Phelps, the Supreme Court had to decide whether a contract made in New York was valid under Connecticut law or not. The plaintiff, Morehouse, argued that he and Phelps had entered into an agreement for him to purchase certain real estate in Connecticut from Phelps at a set price and on specific terms; however, when it came time for payment, Phelps refused to accept it as he claimed that such contracts were invalid under Connecticut law due to their lack of consideration. The court ultimately ruled against Morehouse's argument and held that since there was no consideration given by either party upon entering into the contract – which is required by both New York and Connecticut laws – then the contract could not be enforced in either state’s courts regardless of where it originated from or what its terms may have been.

In the case of Dickerson B. Morehouse v. William A. Phelps, the Supreme Court was asked to decide whether a contract between two parties could be enforced if it had been made without consideration and in violation of a state statute prohibiting such contracts. The majority opinion held that since there was no consideration for the contract, it could not be enforced by either party; however, Justice Grier dissented from this decision on several grounds. He argued that although there may have been no legal consideration given for the agreement, both parties had received something valuable - namely peace of mind and security against future litigation - which should count as sufficient consideration to uphold their bargain in court despite its illegality under state law. Furthermore, he noted that while states are free to pass laws regulating private agreements between individuals within their borders, they cannot prevent citizens from entering into valid contracts with each other outside those boundaries or interfere with existing obligations created by such arrangements when they do occur inside them; thus any attempt to invalidate an otherwise legitimate agreement based solely on its noncompliance with local statutes would amount to an unconstitutional infringement upon Congress' exclusive power over interstate commerce and foreign affairs granted by Article I Section 8 of the Constitution