The Gaming Act 1845 section 19 abolished the feigned issue and provided that the issue should the directly state the question of fact in dispute instead of a wager. The same abolition occurred in New York by section 72 of the Field Code in 1850. In Watt v Starke 101 U.S. 247 (1879) the United States Supreme Court stated "the verdict of a jury upon an issue out of chancery is only advisory."