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Wells v. Nickles is a United States Supreme Court case that was decided in 1881. The case involved a dispute between two parties over a contract for the sale of a steamboat. The plaintiff, Wells, was the owner of the steamboat and had entered into a contract with the defendant, Nickles, to sell the boat for a certain price. Nickles had paid a portion of the purchase price, but had failed to pay the remainder. Wells then brought suit against Nickles for breach of contract. The Supreme Court held that the contract between Wells and Nickles was valid and enforceable. The Court found that the contract was supported by consideration, meaning that both parties had given something of value in exchange for the contract. The Court also found that the contract was not void for lack of mutuality, meaning that both parties had agreed to the same terms and conditions. Finally, the Court held that Wells was entitled to damages for Nickles’ breach of contract. The Court found that Wells was entitled to the unpaid portion of the purchase price, as well as any other damages that he had suffered as a result of Nickles’ breach. The Court also held that Wells was entitled to interest on the unpaid portion of the purchase price. In conclusion, the Supreme Court held that Wells was entitled to damages for Nickles’ breach of contract. The Court found that the contract between the two parties was valid and enforceable, and that Wells was entitled to the unpaid portion of the purchase price, as well as any other damages that he had suffered as a result of Nickles’ breach.
Justice Field delivered the dissenting opinion in Wells v. Nickles, arguing that the majority had misinterpreted a key phrase of the 1866 Civil Rights Act. The act stated that all persons within the jurisdiction of any state should be entitled to "the full and equal benefit of all laws and proceedings for security of person and property." Field argued that this language did not guarantee African Americans access to public accommodations such as inns or theaters, but rather only protected their right to own property without discrimination based on race. He further noted that Congress had never passed legislation specifically granting African Americans access to public accommodations, so it was inappropriate for courts to interpret existing law as doing so. As such, he concluded that there was no legal basis for requiring an innkeeper or theater owner in California (where this case originated) from denying service based on race alone.