In 1788 the Court of Common Pleas, after lengthy deliberations, came to a judgement in Steel v. Houghton et Uxor, concluding that ‘no person has, at common law, a right to glean in the harvest field’. Gleaning was of considerable importance to many labouring families in the eighteenth century; therefore, both the provincial and the London-based newspapers reported the 1788 judgement at length, as well as covering the 1786 case of Worlledge v. Manning on which it was partly based. The 1788 case not only stimulated a widespread public debate over the gleaners’ rights, but also established an important legal precedent. From 1788 onward, every major legal handbook from Burn's New Law Dictionary of 1792 to the early twentieth-century editions of Wharton's Law Lexicon used it as the standard case law reference. It is quoted in a wide variety of law books written for farmers such as Williams's Farmers’ Lawyer and Dixon's Law of the Farm, as well as inspiring long footnotes in the post-1788 editions of Blackstone's Commentaries. By 1904, it was being referred to in the law reports as ‘the great case of gleaning’.

Steel was not an isolated case. During the eighteenth and early nineteenth centuries, the labouring poor in many parts of England not only endured irregular employment and inadequate wages, but also suffered a series of attacks on their customary rights.