The Supreme Court is established by Article III, Section 1 of the Constitution of the United States, which says: "The judicial Power of the United States, shall be vested in one supreme Court .

The size of the Court is not specified; the Constitution leaves it to Congress to set the number of justices.

Other courts noted shortly afterwards that the invocation of unconscionability seemed to conflict with the Court's holding 13 years earlier in United States v. Throckmorton that equitable relief could not be granted in cases of intrinsic fraud.

The Court was asked later in Graver v. Faurot to reconcile the two cases, but declined.

The change resulted in an immediate reduction in the Supreme Court's workload (from 623 cases filed in 1890 to 379 in 1891 and 275 in 1892).