In the case of James B. Teller and Thomas W. Swinney v Jonathan T. Patten and John J. Lane, the Supreme Court was asked to decide whether a contract between two parties could be enforced when one party had not received any benefit from it or been damaged by its breach. The plaintiffs argued that they were entitled to damages for breach of contract because they had provided goods in exchange for an agreement that was never fulfilled by the defendants, who refused to pay them as promised under their original agreement. The court held that there must be some detriment suffered by one party before a valid cause of action can exist; thus, since no harm had been done to either side in this particular situation, neither plaintiff nor defendant could recover damages from each other based on their contractual obligations alone without proof of actual damage incurred due to non-performance or breach thereof..

The dissenting opinion in the case of James B. Teller and Thomas W. Swinney v Jonathan T. Patten and John J Lane was written by Justice Catron, who argued that the majority's decision to reverse a lower court ruling was incorrect because it failed to consider an important point of law: whether or not the plaintiffs had established their right to possession of certain lands under a valid title from Mexico prior to its cession to the United States as part of the Treaty of Guadalupe Hidalgo in 1848. He noted that while there were some discrepancies between what each party claimed, they should have been resolved through further proceedings rather than simply reversing without considering all relevant facts and evidence presented at trial. In conclusion, he stated that if this issue had been properly addressed then perhaps a different outcome would have resulted which is why he felt compelled to dissent from his colleagues' decision on this matter.