In the case of Richard Smith, Lessee of John Lanning v. John Vaughan et al., Smith was suing for possession and damages to a tract of land in Kentucky that he had leased from Lanning. The defendants argued that they were entitled to the property because their ancestor had purchased it prior to Lanning's lease with Smith. The Supreme Court ruled in favor of Smith, finding that his rights under the lease superseded any claims made by the defendants based on their ancestor's purchase since there was no evidence presented showing an actual transfer or conveyance between them and their ancestor. Furthermore, even if such a transfer did exist, it would have been void due to its violation of Kentucky law which prohibited transfers without proper registration at court house offices within one year after purchase date.

In Richard Smith, Lessee of John Lanning v. John Vaughan et al., the Supreme Court was tasked with determining whether a deed from one party to another could be considered valid if it had not been recorded in the county where it was executed. The majority opinion held that such deeds were invalid and unenforceable, but Justice McLean dissented on this point. He argued that while recording should generally be done for purposes of notice, there are cases when an agreement between two parties is sufficient to establish its validity without being recorded; he cited examples such as contracts made under seal or those involving real property which have been delivered and accepted by both parties as evidence of their intent to enter into a binding agreement. Furthermore, he noted that requiring all agreements to be recorded would place an undue burden on individuals who may lack access or resources needed for doing so. Therefore, Justice McLean concluded that even though recording is preferred practice in most circumstances, it should not always be necessary for establishing legal enforceability of certain types of agreements.