In Orchard v. Hughes, the Supreme Court of the United States ruled that a contract between two parties was not binding if it had been made under duress or coercion. The case involved an agreement between William Orchard and John Hughes in which Orchard agreed to pay $2,000 for land owned by Hughes. However, when he refused to make payment on the contract due to financial hardship caused by his business failing during a period of economic depression, Hughes sued him for breach of contract. The court found that because there were no other options available at the time and because Orchard was forced into signing this agreement out of desperation rather than free will, it could not be enforced as a valid legal document. This ruling established an important precedent regarding contracts entered into under duress or coercion being unenforceable in U.S courts going forward

In the case of Orchard v. Hughes, Justice Field delivered a dissenting opinion in which he argued that the majority had failed to properly interpret and apply the law. He asserted that under existing statutes, an individual who was not a citizen at the time of his enlistment could still be considered a soldier for purposes of receiving pay and other benefits after being discharged from service. Furthermore, even if such an individual were deemed ineligible for these benefits due to their lack of citizenship status at enlistment, they should still be able to receive them if they subsequently became naturalized citizens while serving in active duty or within one year thereafter as provided by statute. The majority's decision did not take into account this provision nor any other relevant laws pertaining to military personnel rights; thus Justice Field concluded it was wrongfully decided and should have been reversed on appeal.