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In United States v. Chouteau, the Supreme Court of the United States was asked to decide whether the United States had the right to bring a suit against a private citizen for the recovery of money due to the United States. The case involved a contract between the United States and Pierre Chouteau, Jr., a private citizen, for the delivery of certain goods to the United States. The United States alleged that Chouteau had failed to deliver the goods as promised and sought to recover the money due to it. The Supreme Court held that the United States had the right to bring a suit against a private citizen for the recovery of money due to the United States. The Court reasoned that the United States had the right to bring a suit against a private citizen for the recovery of money due to the United States because the United States was a sovereign and had the right to enforce its contracts. The Court further held that the United States was not required to bring a suit in a state court, but could bring a suit in a federal court. The Court's decision in United States v. Chouteau established that the United States had the right to bring a suit against a private citizen for the recovery of money due to the United States. This decision has been cited in numerous subsequent cases and has been used to support the principle that the United States has the right to enforce its contracts.
In United States v. Chouteau, the Supreme Court was asked to decide whether a treaty between the United States and certain Indian tribes in 1866 extinguished an earlier treaty from 1833 that had granted land rights to those same tribes. The majority opinion held that the later treaty did indeed extinguish all prior treaties with respect to land rights, but Justice Field dissented on this point. He argued that while it is true that subsequent treaties can supersede previous ones, they must do so explicitly or by necessary implication; otherwise, any new agreement would be interpreted as simply adding onto existing obligations rather than replacing them entirely. Furthermore, he noted that if Congress intended for the later treaty to replace all prior agreements related to land rights then it should have done so more clearly in order for there not be any confusion about its intent. Thus, Justice Field concluded his dissent by stating his belief that since no such explicit language existed in either of these two treaties at issue here – nor was there any clear indication of congressional intent – then both should remain valid and enforceable under law.