Specific-Performance

The movement claim that Willard v. Tayloe, 75 U.S. 557 (1869), establishes federal paper-currency authority as limited to the District of Columbia is unsupported

Byron Beers's Treatise #1 (and adjacent alternate-currency literature) cites Willard v. Tayloe for the proposition that federal paper-currency legal-tender authority derives only from Congress's exclusive jurisdiction over the District of Columbia (Art. I § 8 cl. 17), and was unconstitutionally expanded to the states by 'legal fiction.' The structural argument requires that Willard actually establish a D.C.-confined paper-currency authority. It does not. The case was a specific-performance equity suit over a real-estate option in D.C., made under a covenant predating the Legal Tender Act. The Supreme Court, per Justice Field, reversed below and ordered specific performance — but conditioned it on payment in gold and silver coin. The Court expressly declined to rule on the constitutionality of the Legal Tender Act. The attributed quote ('These terms unquestionably include the power to make treasury notes legal tender for all debts') does not appear in the opinion.