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Maynard v. Hill

United States Supreme Court
125 U.S. 190 (1888)



In 1850, David S. Maynard abandoned his first wife, Lydia A. Maynard, and moved from Ohio to Oregon Territory. In April 1852, Oregon awarded David and his wife equal shares in 640 acres of land, provided that he farm the tract until April 1856. In December 1852, the Oregon legislature passed special legislation dissolving the Maynards' marriage, and David remarried in 1853. In April 1856, David completed the four-year term of cultivation required to obtain title to his tract. However, after complex procedural hearings, state officials determined that neither of David's two wives was entitled to a half portion of the tract, since neither wife was married to David for the entire four-year term. Oregon sold the forfeited half portion to Hill and Lewis (defendants). Lydia died in 1879, and her children, Henry C. Maynard and Frances J. Patterson (plaintiffs), sued Hill and Lewis for ownership of the half portion. Both the trial court and the Supreme Court of the Washington Territory denied the children's claim, and they appealed to the United States Supreme Court. The Court noted that Congress prohibited Oregon's legislature from impairing contracts but otherwise did not restrict the legislature's power to dissolve marriages.

Rule of Law


Holding and Reasoning (Field, J.)

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