In the case of Henry Wheaton and Robert Donaldson v. Richard Peters and John Grigg, two authors brought a suit against two publishers for copyright infringement. The authors argued that their copyrights had been violated when the defendants published an unauthorized edition of their work without permission or compensation to them as the rightful owners. The Supreme Court held in favor of the plaintiffs, finding that they were entitled to damages for violation of their exclusive right to publish under federal law. This decision established important precedent regarding copyright protection in America by recognizing that such rights are protected under federal law even if state laws do not provide similar protections at the time.

In Henry Wheaton and Robert Donaldson v. Richard Peters and John Grigg, the Supreme Court was asked to decide whether a reporter of decisions for the United States Circuit Courts had exclusive rights to publish those reports. The majority opinion held that no such right existed; however, Justice Story dissented from this decision. He argued that reporters should have exclusive rights in order to protect their laborious efforts in compiling these reports as well as incentivize them to continue doing so with accuracy and diligence. Furthermore, he noted that Congress had previously granted exclusive copyright privileges on similar works which suggested they intended for there to be some form of protection over these published materials. Ultimately, Justice Story concluded by asserting his belief that it would be unjust not recognize any sort of privilege or reward for the hard work put into producing accurate legal documents like court opinions and other judicial records.