In an early landmark case for the U. S. Supreme Court the state of Georgia refused to reimburse South Carolina merchant Robert Farquhar for goods it had ordered in 1777, during the American Revolution. Alexander Chisholm, representing what was now the estate of Farquhar, sought a writ of inquiry from the court.

Represented before the court by Attorney-General Edmund Randolph, the 5-member court ruled 4-1 against Georgia, who had refused to send a representative. Following the Supreme Court decision, three states proposed an amendment to codify the ruling. This became the 11th Amendment to the U. S. Constitution.