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In the case of William A. Smith and Others v. Lerox Swormstedt and Others, the Supreme Court was tasked with determining whether a deed for land in Ohio that had been executed by an Indian tribe to two individuals was valid or not. The court held that since the Indians were considered wards of the United States government, they could not enter into any contract without approval from Congress first; therefore, this particular deed was invalid as it had never received such approval. Furthermore, even if it did receive congressional approval at some point in time, it would still be void because no consideration (money) had ever been exchanged between parties involved in executing said deed. This decision set a precedent for future cases involving contracts made with Native Americans who are under federal protection due to their status as wards of the United States government
In the case of William A. Smith and Others v. Lerox Swormstedt and Others, Chief Justice Taney delivered a dissenting opinion in which he argued that Congress had no authority to pass an act allowing for the recovery of damages from individuals who were responsible for causing injury or death to slaves while they were being transported across state lines. He further argued that such an act would be unconstitutional because it would interfere with the rights of slaveholders as protected by Article IV, Section 2 of the Constitution, which states that “the citizens of each State shall be entitled to all privileges and immunities” regardless if they are free or enslaved persons. Additionally, Chief Justice Taney asserted that any attempt by Congress to regulate slavery was beyond its power since this matter fell under state jurisdiction according to Article I, Section 8 Clause 17 (known as The Fugitive Slave Clause). Therefore, he concluded that Congress could not pass laws regulating slavery without violating both Articles IV and I Sections 8 Clauses 17 & 18 respectively.