It was a case that hinged mainly on procedural issues relating to the documents that must accompany an appeal from courts within the District of Columbia.

[1] The Supreme Court had already ruled in Jennings v. The Perseverance, 3 U.S. (3 Dall.)

[2] The act of Congress 27 February 1801, creating the District of Columbia held that, writs should be prosecuted in the same manner as had been the case of writs of error on judgments or appeals upon orders or decrees rendered in the circuit court of the United States.

[1] The court held that the act of congress and the prior precedent, when taken together meant that all appeals from the District of Columbia must be accompanied by a statement of facts.

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