Adams v. Burke was a United States Supreme Court case that addressed the issue of whether a state court had the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The case arose when a prisoner, John Adams, was held in a federal prison in the state of Georgia. Adams sought a writ of habeas corpus from the state court, claiming that he was being held in violation of the Constitution. The state court granted the writ, and the federal government appealed the decision to the Supreme Court. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The Court reasoned that the writ of habeas corpus was a federal prerogative, and that the state court did not have the authority to interfere with the federal government's power to imprison individuals. The Court also noted that the writ of habeas corpus was a fundamental right, and that the state court should not be allowed to interfere with the federal government's power to protect the rights of individuals. In conclusion, the Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The Court reasoned that the writ of habeas corpus was a federal prerogative, and that the state court did not have the authority to interfere with the federal government's power to imprison individuals. The Court also noted that the writ of habeas corpus was a fundamental right, and that the state court should not be allowed to interfere with the federal government's power to protect the rights of individuals.

Justice Field delivered the dissenting opinion in Adams v. Burke, arguing that the majority's decision was contrary to established precedent and would lead to an unjust result. He argued that under prior decisions of this Court, a party who had been wrongfully dispossessed of land could bring suit against any person who had taken possession of it without legal authority or justification. In this case, he noted that the plaintiff had obtained title from a third party before being dispossessed by defendants; thus, they were not liable for his damages as they did not take possession unlawfully. Furthermore, Justice Field argued that even if there was some defect in plaintiff’s title at the time he was dispossessed by defendants—which is unclear from the record—the proper remedy would be for him to seek relief through ejectment rather than damages since no one else has asserted superior rights over those lands since then. Therefore, Justice Field concluded that judgment should have been entered in favor of defendants and against plaintiffs on their claim for damages arising out of wrongful dispossession