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Schell v. Cochran was a United States Supreme Court case that addressed the issue of whether a state court could enforce a contract that was made in violation of a state statute. The case involved a contract between two parties, Schell and Cochran, in which Schell agreed to pay Cochran a certain amount of money for the sale of a piece of property. The contract was made in violation of a state statute that prohibited the sale of property without a license. The state court enforced the contract, and Cochran sued Schell for the money owed. The Supreme Court held that the state court had the authority to enforce the contract, despite the fact that it was made in violation of the state statute. The Court reasoned that the state statute was not intended to invalidate contracts, but rather to regulate the sale of property. Therefore, the Court concluded that the state court had the authority to enforce the contract. The Court also noted that the state statute did not provide any remedy for the violation of the statute, and thus the state court was the only avenue for Cochran to seek redress.
Justice Field delivered the dissenting opinion in Schell v. Cochran, arguing that the majority's decision was contrary to established precedent and would lead to an unjust result. He argued that under prior decisions of the Supreme Court, a party could not be held liable for damages resulting from their own negligence when they had no control over another person who caused harm through their own negligent acts. In this case, he argued that since Cochran had no control over Schell's actions or his horse-drawn wagon which caused injury to plaintiff's property, he should not be held liable for any damage done by them. Furthermore, Justice Field noted that even if there were some degree of responsibility on Cochran’s part due to his failure to warn about potential dangers posed by Schell’s wagon passing through his land (which is what the majority found), it did not rise above mere contributory negligence and thus should have been disregarded as a matter of law according to prior cases decided by the court. Ultimately Justice Field concluded with a warning against allowing such decisions as this one “to stand without correction," noting how it would lead "to injustice in many instances."