In Sweeny et al. v. Easter, the Supreme Court of the United States was asked to decide whether a state court had jurisdiction over an action brought by a non-resident against another non-resident in which both parties were citizens of different states and neither party resided in the forum state. The Court held that such actions could not be maintained in any court within the United States unless there was some special act or law authorizing it, as no general power existed for one State to exercise jurisdiction over persons who did not reside therein and whose only connection with it arose out of transactions occurring outside its limits. Furthermore, even if such authority did exist under certain circumstances, this case failed to present them since none of those involved were residents nor had any property within the forum state's boundaries at issue between them. Thus, because no sufficient basis for exercising jurisdiction existed here, the judgment rendered by said court must be reversed and set aside accordingly.

In Sweeny et al. v. Easter, the Supreme Court was asked to decide whether a deed of trust executed by an emancipated slave in Virginia was valid under the laws of that state. The majority opinion held that it was not, as slaves were considered property and could not enter into contracts or own property themselves. Justice Field dissented from this decision, arguing that even though slavery had been abolished in Virginia at the time of execution, there should be no legal distinction between those who were formerly enslaved and other citizens when it came to their ability to contract or own property. He argued further that if a former slave's deed is invalid because they are unable to legally bind themselves with such agreements then all deeds made by them prior to emancipation would also be void - which he felt would lead to great injustice for many people who had relied on these documents being valid after emancipation occurred.