In the case of William Wheeler v. Hugh Smith and Phineas Janney, Executors of Charles Bennett, Deceased, and Surviving Trustees under his Will, and Molly E. Taylor, Executrix, and Henry Daingerfield and Phineas Janney, Executors of Robert I. Tay (Wheeler v. Smith et al.), the Supreme Court was asked to decide whether a deed from Charles Bennett to William Wheeler was valid or not. The court found that while there had been an agreement between the parties for such a transfer of property rights in 1837 as part of a larger transaction involving other properties owned by both parties at that time; however due to certain conditions which were not fulfilled by either party prior to Mr Bennet's death in 1840 no title could be conveyed from him after his death without formal execution according to law - something which did not occur until 1850 when it was executed by Mr Bennett's executor on behalf of all interested parties involved in this matter including Mr Wheeler who received full legal title over the property he sought ownership over through this ruling .

In the dissenting opinion of William Wheeler v. Hugh Smith and Phineas Janney, Executors of Charles Bennett, Deceased, and Surviving Trustees Under His Will, and Molly E. Taylor, Executrix, and Henry Daingerfield and Phineas Janney, Executors of Robert I. Tay (1850), Justice Catron argued that the majority’s decision was wrongfully based on a misreading of Virginia law as it pertained to the case at hand. He noted that there were two distinct issues in dispute: whether or not an executor could be held liable for debts incurred by their predecessor; and if so under what circumstances? In his view both questions should have been answered in favor of appellant William Wheeler since he had provided sufficient evidence to prove his claim against Charles Bennett's estate prior to its transfer into new hands. Furthermore Justice Catron contended that Virginia law did not require any additional proof from Wheeler beyond what he had already presented before the court which would have allowed him to collect on his debt without further delay or expense.