The Supreme Court's decision declared the blockade of the Southern ports ordered by President Abraham Lincoln constitutional.

At the beginning of the war there was only one significant steel mill and manufactory in the South, the Tredegar Iron Works in Richmond, Virginia.

The question before the court dealt with the seized ships, but it reached widely into the legality of wars against acts of belligerence, whether or not officially declared.

It rose through the lower Federal courts through lawsuits by Northern merchants whose ships were seized by U.S. Navy warships enforcing the blockade.

While the court acknowledged that the United States Congress had, in July 1861, adopted a law ratifying and approving the President's proclamation after the fact, as well as other actions taken since then to prosecute the war, that was not the point.