An insurance company challenged the legitimacy of a sale of property approved by a Florida territorial court, claiming that the court had not been competent to act because its judges lacked tenure during good behavior pursuant to Article III of the Constitution. The Supreme Court ruled the sale valid, however. In his opinion for the Court, Chief Justice John Marshall explained that the requirements of Article III, including tenure during good behavior, did not apply in the territories. The case set a precedent that adjudication by non-Article III “legislative courts” was permissible under certain circumstances.

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