In Parker v. Morrill, the Supreme Court of the United States was asked to decide whether a contract between two parties was valid. The contract in question was between the plaintiff, Parker, and the defendant, Morrill. Parker had agreed to sell Morrill a tract of land for a certain sum of money. Morrill had paid the money, but Parker refused to deliver the deed to the land. The Supreme Court held that the contract was valid and enforceable. The Court found that the contract was supported by consideration, meaning that both parties had given something of value in exchange for the other's promise. The Court also found that the contract was not void for lack of mutuality, meaning that both parties had agreed to the same terms. The Court also held that Parker was obligated to deliver the deed to Morrill. The Court found that Parker had accepted the money and had not objected to the terms of the contract. Therefore, the Court held that Parker was obligated to fulfill his part of the contract and deliver the deed to Morrill.

Justice Field delivered the dissenting opinion in Parker v. Morrill, arguing that the majority's decision was wrongfully based on a misreading of the contract between parties. He argued that under California law, which applied to this case, an agreement for sale of land could not be enforced unless it was in writing and signed by both parties. In this case, there had been no such written agreement; instead, one party had simply made an offer to purchase land from another party who accepted verbally but never followed through with any further action or paperwork. Justice Field argued that since there was no written contract between them as required by California law at the time, neither party should have been able to enforce their rights against each other and thus they were both entitled to recover what they paid out during litigation over ownership of the property. Ultimately he concluded that while verbal agreements may sometimes be binding depending on circumstances surrounding them (such as part performance), here there had been none so neither side should prevail in court proceedings over ownership rights related to this particular piece of real estate.