In Seth Spring and Sons v. The South Carolina Insurance Company, Gray & Pindar, William Lindsay, and John Haslett (1823), the Supreme Court of the United States heard a case involving an insurance policy dispute between two parties. Appellant Seth Spring and Sons had taken out an insurance policy with Respondents The South Carolina Insurance Company to cover their ship's voyage from Charleston to Liverpool in 1820. When the ship was lost at sea due to a storm, Respondents refused payment on the grounds that they were not liable for losses caused by "perils of navigation." Appellants argued that this exclusion clause did not apply because it was only meant for ships navigating inland waters rather than those travelling overseas. In its ruling, the court held that since there is no distinction made in maritime law between inland voyages and foreign voyages when it comes to perils of navigation exclusions clauses, Respondent’s refusal of payment was valid under existing laws governing marine insurance policies.

In the case of Seth Spring and Sons v. The South Carolina Insurance Company, Gray & Pindar, William Lindsay, and John Haslett, the dissenting opinion argued that a contract between two parties should be enforced even if it is not in writing. In this particular case, Seth Spring had agreed to pay for insurance coverage from The South Carolina Insurance Company but failed to do so after receiving payment from his customer who was insured by them. Justice Johnson argued that an oral agreement can still be binding as long as there is evidence of mutual assent between both parties; therefore he believed that Seth Spring should have been held liable for their failure to fulfill their contractual obligations despite not having a written agreement in place. He also noted that any ambiguity or uncertainty surrounding the terms of such contracts could easily be resolved through legal proceedings rather than disregarding them altogether.