The United States Supreme Court case of The United States v. Frances Richard involved a dispute over the ownership of land in Mississippi. At issue was whether or not the federal government had authority to grant lands that were previously owned by Native Americans, and if so, who held title to those lands after they were granted. The court found that Congress did have authority to grant such lands, but only when it was done with consent from both parties and for just compensation. Furthermore, the court ruled that any grants made without proper consent would be voidable at law and could be challenged by either party in a subsequent lawsuit. In this particular case, since there was no evidence of an agreement between Richard and the U.S., she retained her rights as owner of the property in question despite having received a patent from Congress granting her title to it years earlier.

In the United States v. Frances Richard, the Supreme Court was asked to decide whether a federal court had jurisdiction over an action brought by a private citizen against another private citizen in which the plaintiff sought damages for breach of contract. The majority opinion held that such actions were not within the scope of federal judicial power and must be heard in state courts. Justice McLean dissented from this decision, arguing that Congress has authority under Article III of the Constitution to grant original jurisdiction to federal courts over cases involving contracts between citizens of different states or foreign countries. He argued further that it would be unjust for parties who have entered into valid contracts with each other to be denied access to justice because they are unable or unwilling to bring their claims before state courts due solely to jurisdictional issues. Therefore, he concluded, Congress should exercise its constitutional powers and provide relief through granting original jurisdiction over these types of cases in federal court so as not deprive individuals their right “to seek redress” when wronged by another party's breach of contract.