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Patton v. Nicholson was a case heard by the United States Supreme Court in 1818. The dispute arose from a contract between Patton and Nicholson, which provided that Patton would pay $2,000 for land owned by Nicholson located in Kentucky. After paying part of the purchase price to Nicholson, Patton refused to make further payments due to his belief that he had not received title or possession of the property as promised under their agreement. The court held that although there was no express warranty given by either party regarding title or possession of the property at issue, an implied warranty existed such that if one party pays money for something they should receive what they paid for unless otherwise agreed upon beforehand. Therefore, because it could be inferred from their agreement that both parties intended for Patton to have full title and possession of the land after making payment according to terms set forth in their contract, he was entitled to recover damages against Nicholson based on breach of this implied warranty.
In Patton v. Nicholson, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a citizen of another state against a resident of the forum state. The majority opinion held that it did not, as such suits were prohibited under Article III of the Constitution and could only be heard in federal courts. Justice Johnson dissented from this decision, arguing that while Congress has exclusive power to regulate interstate commerce and disputes between citizens of different states, there is no constitutional provision which prohibits states from exercising their own judicial powers in matters involving their own citizens or those who are present within its borders at any given time. He further argued that if Congress intended for all such cases to be decided exclusively by federal courts then they would have included language specifically stating so in Article III; since they did not do so he concluded that individual states should retain authority over these types of cases unless otherwise specified by law or treaty.