In Nathan Carr and Others v. Joseph Hoxie, the Supreme Court of the United States was asked to decide whether a contract between two parties could be enforced when it had been made without consideration. The appellants argued that they had entered into an agreement with appellee Joseph Hoxie in which he agreed to pay them for certain services rendered by them on his behalf. However, since there was no consideration given for this agreement, they claimed that it should not be enforceable under law. The court disagreed and held that although there may have been no consideration exchanged at the time of making the contract, if both parties intended to enter into a binding agreement then it would still be valid even without any form of payment or exchange being involved. This decision established an important precedent in American contract law which has stood ever since; namely that agreements can still be legally binding even if one party does not receive anything in return from another party as long as all other elements are present such as mutual assent and capacity to enter into contracts

In the case of Nathan Carr and Others v. Joseph Hoxie, Appellee, the Supreme Court was asked to decide whether a deed from an Indian tribe to an individual could be enforced in court. The majority opinion held that such deeds were not enforceable because they had been made without consideration or any other legal formality. However, Justice McLean dissented from this decision on the grounds that it would be unjust for courts to refuse enforcement of these deeds when Indians had relied upon them as valid contracts and acted accordingly. He argued that if individuals are allowed to make contracts with each other without consideration then why should Indians not have similar rights? Furthermore, he noted that treaties between tribes and states often involve exchanges of land which implies recognition by both parties of their ability to enter into binding agreements regarding property rights. Therefore, Justice McLean concluded that Indian deeds should be treated like any other contract under state law and enforced according to its terms unless there is clear evidence demonstrating fraud or duress on behalf of either party involved in making it.