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 mitigate the ruling. This became the 11th Amendment to the U. S. Constitution.

The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.