In the case of William W. Watts and Arthur Watts' Executors, et al v. William Waddle and Alexander Waddle's Administrators, et al., two families were in dispute over a tract of land located in Tennessee that had been owned by John Watts before his death. The heirs of John Watts argued that they should have inherited the property through their father’s will while the other family claimed it was part of an estate left to them by their deceased relative, John Waddle. After much deliberation, the Supreme Court ruled in favor of the heirs of John Watt due to evidence showing that he had acquired title to said land prior to his death and thus could pass it on as inheritance according to his will.

In the dissenting opinion of William W. Watts and Arthur Watts' Executors v. William Waddle and Alexander Waddle's Administrators, Justice Story argued that the lower court had erred in its decision to grant a motion for judgment on the pleadings in favor of the defendants. He believed that there were sufficient facts presented by both parties which should have been considered before making such a ruling, as it was impossible to determine who held title to certain lands without further evidence being provided or examined. Furthermore, he contended that even if one party did possess superior rights over another with regard to these lands, this could not be determined until after an examination into all relevant documents and testimony from witnesses had been conducted at trial. Therefore, he concluded that summary judgment was inappropriate under these circumstances and should have been denied by the lower court so as to allow for further proceedings regarding ownership of said property between both parties involved in this dispute.