Chase ruled that leaving the Union was possible only through rebellion or with the consent of the other states. No "might makes right" in the decision anywhere.
His argument is one of might makes right - not government derives its legitimacy from the consent of the governed.
The main difference between 1776 and 1861 is that in 1861 there wasnt a rival superpower willing to shovel money and supplies and guns at the secessionists and lend them troops and lend them their navy. The other main difference is that the states were sovereign and had the right to secede while the colonies were not and did not have a legal right to secede.