In the case of John A. Warner, et al v Thomas P. Martin, citizens from Pennsylvania and Virginia were involved in a dispute over an unpaid debt owed by Martin to Franklin (who had since passed away). The appellants argued that they should be able to collect on the debt due to their status as creditors of Franklin's estate; however, Martin countered that he was not liable for any debts incurred prior to his partnership with Franklin. Ultimately, the Supreme Court ruled in favor of the appellants and held that all parties who had contracted with Franklin before his death were entitled to payment from his estate regardless of whether or not they were aware of any subsequent partnerships between him and other individuals.

In the dissenting opinion of this case, Justice McLean argued that the Circuit Court of Pennsylvania had no jurisdiction over Thomas P. Martin, a citizen of Virginia who survived Spencer Franklin and was trading under the firm name Martin and Franklin. He believed that since none of the parties involved were citizens or residents in Pennsylvania, it was not within their power to bring suit against someone from another state. Furthermore, he stated that if any court did have authority to hear such a case it would be one located in Virginia where both parties resided rather than Pennsylvania which had no connection with either party. Justice McLean concluded by saying that allowing courts outside their own jurisdictions to preside over cases involving non-residents could lead to confusion and injustice for all those involved.