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In Northwestern Union Packet Company v. Viles, the Supreme Court of the United States was asked to decide whether a contract between a steamship company and a passenger was valid. The passenger, Viles, had purchased a ticket from the steamship company, Northwestern Union Packet Company, for a voyage from New York to Liverpool. The ticket contained a clause that stated that the steamship company was not liable for any damages caused by the negligence of its servants. Viles was injured during the voyage and sued the steamship company for damages. The Supreme Court held that the contract between the steamship company and Viles was valid and enforceable. The Court found that the clause in the ticket was not an attempt to exempt the steamship company from liability for its own negligence, but rather was an attempt to limit the amount of damages that could be recovered in the event of an injury. The Court also held that the clause was not unconscionable or against public policy. Therefore, the Court held that the steamship company was not liable for Viles' injuries.
In Northwestern Union Packet Company v. Viles, the Supreme Court was asked to decide whether a contract between two parties could be enforced when it had been made without consideration and in violation of a state statute. The majority opinion held that the contract was unenforceable because it lacked consideration and violated public policy as expressed by the state law. However, Justice Field dissented from this decision on several grounds. He argued that although there may have been no actual consideration for making the agreement, its performance would benefit both parties; thus, he believed that equity should allow enforcement of such contracts if they are not against public policy or morals. Furthermore, he noted that even though one party may have acted illegally in entering into an agreement with another party who did not know about any illegality at the time of contracting, courts should still enforce such agreements unless their terms are unconscionable or contrary to public policy or morals.