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Totten, Administrator, v. United States

• 1875 • 92 U.S. 105 • Waite Court
Totten v. United States was a United States Supreme Court case that addressed the issue of whether a contract between a private individual and the United States government was enforceable. William W. Totten was the administrator of the estate of George W. Totten, who had entered into a contract with the United States government in 1861. The contract was for the purpose of providing secret service to the government during the Civil War. The contract was never fully performed, and the government...Open Case
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Chief Waite Court
Term: 1875
Docket: 167
92 U.S. 105
23 L. Ed. 605
1875 U.S. LEXIS 1732
Argued: Mar 15, 1876

Totten, Administrator, v. United States

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Opinion Summary
AI Abstract

Totten v. United States was a United States Supreme Court case that addressed the issue of whether a contract between a private individual and the United States government was enforceable. William W. Totten was the administrator of the estate of George W. Totten, who had entered into a contract with the United States government in 1861. The contract was for the purpose of providing secret service to the government during the Civil War. The contract was never fully performed, and the government refused to pay the estate for the services rendered. The Supreme Court held that the contract was enforceable, and that the government was liable for the services rendered. The Court reasoned that the contract was valid and binding, and that the government was obligated to pay for the services rendered. The Court also held that the contract was not subject to the statute of frauds, as it was not a contract for the sale of goods or services. The Court further held that the contract was not subject to the statute of limitations, as it was not a contract for the sale of goods or services. In conclusion, the Supreme Court held that the contract between the United States government and George W. Totten was enforceable, and that the government was liable for the services rendered. The Court reasoned that the contract was valid and binding, and that the government was obligated to pay for the services rendered.

Dissent Summary
AI Abstract

In Totten v. United States, the Supreme Court was asked to decide whether a contract between President Lincoln and William P. Totten for secret services during the Civil War could be enforced by his administrator after his death. The majority opinion held that it could not because such contracts were too uncertain in their terms and would require an inquiry into confidential matters which should remain private. However, Justice Field dissented from this decision on two grounds: firstly, he argued that there was no reason why such a contract should not be enforceable if it had been properly executed; secondly, he noted that even if the contract did lack sufficient certainty of terms to make it legally binding under ordinary circumstances, Congress had passed legislation specifically authorizing payment for these kinds of services rendered during wartime so as to protect those who risked their lives in service of their country without expecting any reward or recognition for doing so. Thus, Justice Field concluded that since Congress had already provided legal protection for these individuals through its legislation then they ought also have access to judicial remedies when necessary - something which would only be possible if contracts like this one were allowed to stand despite any uncertainty surrounding them.

Opinion written by Justice SJField
Decided: Apr 10, 1876
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