In Robert Steele's Lessee vs. Jesse Spencer and Others, the Supreme Court was asked to decide whether a deed of trust created by an individual in Virginia was valid under Pennsylvania law. The plaintiff argued that the deed should be considered valid because it had been executed according to Virginia law, while the defendants argued that it did not meet Pennsylvania requirements for such deeds. Ultimately, the court found in favor of the plaintiff and held that since there were no specific laws governing trusts in either state at issue, then both states must recognize each other’s laws on this matter as long as they are consistent with their own public policy. This ruling established a precedent for recognizing contracts between two different states when those contracts do not violate any existing state or federal laws.

In Robert Steele's Lessee v. Jesse Spencer and Others, the Supreme Court was tasked with determining whether a deed of trust made by an individual could be enforced against his heirs after his death. The majority opinion held that the deed of trust was valid and enforceable against the heirs, but Justice Johnson dissented from this ruling. He argued that since there is no law in Virginia which allows for such a transfer to take place without being specifically stated in writing, it should not be allowed here either. Furthermore, he noted that allowing such transfers would create uncertainty as to who holds title to property when someone dies intestate or without leaving any written instructions regarding their estate plan. Ultimately, Justice Johnson concluded that while deeds of trust may have been recognized at common law prior to 1792 (when Virginia adopted its own laws), they are not currently recognized under state statute and therefore cannot be enforced against an individual’s heirs after their death.