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In Lewis Rogers v. Joseph G. Lindsey, Henry S. Atwood, and John S. Bennett, the Supreme Court of the United States was asked to determine whether a contract between two parties could be enforced by one party against another when it had been signed without consideration or value given in exchange for its execution. The appellant argued that he had entered into an agreement with the appellees whereby they would pay him $1,000 if he agreed to convey certain lands owned by him to them; however, no payment was ever made and thus there was no consideration for his promise to transfer title of said lands. The court held that although there may have been a valid contract between the parties at some point in time prior to its execution due to their mutual promises and intentions regarding said land transaction, such agreement became unenforceable once it was executed without any valuable consideration being exchanged as required under law at that time period in order for contracts involving real estate transactions were enforceable upon delivery of deed from grantor (appellant)to grantee (appellees).
In the case of Lewis Rogers v. Joseph G. Lindsey, Henry S. Atwood, and John S. Bennett, Justice McLean delivered a dissenting opinion in which he argued that the lower court had erred in its decision to dismiss Rogers’ claim against his former employers for breach of contract and unjust enrichment due to their failure to pay him wages owed from his employment as an overseer on their plantation in Mississippi between 1847-1848. He reasoned that since there was no dispute over the fact that Rogers had performed labor for them during this period or about how much money they were obligated to pay him according to their agreement, it was wrong for the lower court not only deny him any compensation but also refuse even consider evidence related to damages caused by such nonpayment when determining whether or not he should be awarded relief under state law principles governing contracts and quasi-contracts like those at issue here. Therefore, Justice McLean concluded that justice demanded reversal of this ruling so as allow a jury decide if Rogers deserved some form of recompense from these defendants based on all relevant facts presented before them at trial