Eliza Malloney, Appellant v. John Horan, Respondent

Summary

The New York Court of Appeals reversed the lower court's judgment and ordered a new trial on the plaintiff's dower claim, holding that neither estoppel in pais nor estoppel by record barred her, that her release of dower was only effective by estoppel against parties to the conveyance, and that merger of estates does not defeat her dower. Justice Grover dissented, arguing the plaintiff was bound by the prior judgment.