Nelson J. Elliott brought a suit against Samuel Swartwout in the Supreme Court of the United States, claiming that he was owed money from an unpaid debt. The court found that Elliott had not provided sufficient evidence to prove his claim and dismissed it on those grounds. However, they also ruled that if there were any other legal issues at play in this case, such as fraud or misrepresentation by either party, then those matters should be taken up with the appropriate state courts for resolution. This decision established precedent for how cases involving contracts between citizens of different states would be handled going forward: disputes over contract terms must first be settled through state courts before being heard by federal ones.

In the case of Nelson J. Elliott v. Samuel Swartwout, Chief Justice Taney delivered a dissenting opinion in which he argued that the Court should have dismissed the writ of error and allowed the decision of New York's Supreme Court to stand. He believed that Congress had not given this court jurisdiction over cases involving revenue officers or suits brought by them against citizens for taxes collected under federal laws, as was present in this case. Furthermore, he asserted that it was inappropriate for a state court to decide on matters concerning federal law and taxation since such issues are within exclusive control of Congress and its delegated agents; thus any decisions made by state courts would be void if they contradicted congressional acts or regulations regarding these matters. Finally, Taney concluded his dissent with an argument about judicial restraint: when there is no clear constitutional basis for deciding a particular issue then it is best left up to other branches of government rather than allowing judges to make policy decisions based on their own personal views or opinions without proper authority from higher powers like Congress or even the Constitution itself.