In Yeaton and Others, Claimants of the Schooner General Pinkney and Cargo v. The United States, a dispute arose between private citizens who owned a schooner named the General Pinkney and its cargo on one side, and the United States government on the other. At issue was whether or not those private citizens were entitled to compensation for their losses due to an act of Congress that authorized President Thomas Jefferson to seize all vessels belonging to France during wartime. The Supreme Court ultimately held that although it sympathized with the claimants’ plight, they could not be compensated because their loss resulted from an act of Congress which had been deemed constitutional by another court in 1804. As such, this case established precedent for when individuals may seek damages against acts taken by federal authorities under certain circumstances.

In Yeaton and Others, Claimants of the Schooner General Pinkney and Cargo v. The United States, Justice Johnson delivered a dissenting opinion in which he argued that the Court should have found for the claimants. He maintained that Congress had not intended to exclude vessels from protection under their Neutrality Act when they were captured by an enemy vessel while attempting to escape into neutral waters. Furthermore, he noted that it was unfair for Congress to impose such restrictions on vessels since they could not be expected to know all of its laws or anticipate how those laws would be interpreted by courts. Additionally, Johnson argued that if Congress did intend this exclusion then it should have been made explicit in order for citizens to understand what is required of them when navigating international waters. Finally, he concluded his dissent with a warning about how allowing such exclusions could lead other nations to take similar actions against American ships sailing abroad without any legal recourse available due process protections afforded by U.S law