In Robert H. Wynn, Executor and Devisee of William Wynn, Deceased v. Charles B. Morris et al., the Supreme Court was asked to decide whether a deed from an executor or administrator is valid if it does not contain language explicitly authorizing him to make such a conveyance on behalf of the estate he represents. The court held that when an executor or administrator has been appointed by a court with authority over the estate in question, any deeds executed by them are presumed to be valid unless there is evidence that they were acting outside their scope of authority as determined by state law. Furthermore, even if no explicit authorization exists for making such conveyances, courts may still find them binding under certain circumstances depending on how much control and discretion was given to the executor or administrator in question at the time of appointment.

In this case, Robert H. Wynn, the executor and devisee of William Wynn's will, argued that he was entitled to a tract of land in Virginia under his late father's will. The majority opinion held that the deed for the property had been executed by Morris before William Wynn died and thus could not be affected by his will. However, Justice Grier dissented from this decision on two grounds: firstly, he argued that there was no evidence presented at trial to show when exactly Morris received title to the land; secondly, even if it were true that Morris obtained title prior to William Wynn's death then any rights or interests acquired after his death should still pass through his estate according to Virginia law. Therefore Grier concluded that further proceedings were necessary in order for an accurate determination of ownership over the disputed property could be made.