In Philip Norborne Nicholas, Attorney General of Virginia v. Richard C. Anderson, Surveyor &c., the Supreme Court was asked to determine whether a surveyor’s certificate could be used as evidence in court proceedings. The case arose when Anderson had surveyed land for an individual and issued a certificate that stated the boundaries of the property were correct according to his survey. When this individual attempted to use this certificate as evidence in court proceedings, it was objected by Nicholas on behalf of Virginia who argued that such certificates should not be admissible because they did not meet certain requirements set out by statute law at the time. The Supreme Court ultimately held that while these certificates may have been useful for private purposes between parties involved in disputes over land ownership or boundary lines, they were insufficiently reliable and trustworthy for use as evidence before courts due to their lack of authentication from public officials or other sources outside those directly involved with surveying process itself.

In the case of Philip Norborne Nicholas, Attorney General of Virginia v. Richard C. Anderson, Surveyor &c., the Supreme Court was asked to decide whether a surveyor had authority to make surveys in Virginia without first obtaining permission from the state legislature. The majority opinion held that such permission was required and that any surveys made without it were invalid. However, Justice Johnson dissented on this point and argued that while it may be wise for surveyors to obtain legislative approval before making their surveys, there is no legal requirement for them to do so under existing law or custom in Virginia at the time. He further noted that if such a requirement did exist then it would be an unconstitutional infringement upon individual rights as well as an unreasonable burden on those wishing to conduct business within the state's borders. In conclusion he stated his belief that individuals should have freedom of action when conducting lawful activities unless specifically prohibited by statute or other binding authority