In the case of Jesse Snead, Late High Sheriff of Henrico County and Administrator de bonis non of Albert Seekamp, deceased v. Julia M'Coull, widow of Neil M'Coull, Charles L. M'Coull (Administrator de bonis non for Neil), and The Bank of Virginia in 1851, the Supreme Court was asked to decide whether a bank could be held liable for debts owed by its former president who had died without paying them off. The court ruled that while banks are not responsible for their officers’ personal debts unless they have been specifically authorized or ratified by the board or shareholders as part of their business operations; however if such authorization is given then it can be enforced against both the officer and his estate after death. In this particular case there was no evidence presented that any such authorization had been made so therefore the bank could not be held liable for any debt incurred by its former president prior to his death.

In the dissenting opinion of Jesse Snead, Late High Sheriff of Henrico County and as such, Administrator de bonis non of Albert Seekamp, Deceased v. Julia M'Coull, Widow of Neil M'Coull; Charles L. M'Coull, Administrator de bonis non of Neil M’coull and The (1851), Justice Catron argued that the court should have found in favor for Appellant Jesse Snead because he was not given a fair trial by jury due to improper instructions from the judge presiding over his case. He believed that if proper instructions had been provided to the jury then they would have returned a verdict in favor for Appellant Snead since there were sufficient facts presented at trial which supported his claim against Respondents Julia Mcoll and Charles L. Mcoll who were administrators de bonis non for their deceased husbands estate respectively. Furthermore Justice Catron also noted that even though it may be true that Appellants did not provide evidence regarding certain matters related to this case during trial proceedings; those matters could still be considered by the court when making its decision on appeal since they are relevant to determining whether or not justice has been served in this particular instance.