Alexander v. Bryan was a United States Supreme Court case that dealt with the issue of whether a state court had the authority to issue a writ of habeas corpus to a prisoner who was being held in federal custody. The case arose when a prisoner, Alexander, was held in federal custody in the state of Georgia. Alexander 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 federal custody. The Court reasoned that the writ of habeas corpus was a federal remedy, and that the state court did not have the power to interfere with the federal government's authority to detain a prisoner. The Court also noted that the writ of habeas corpus was a remedy that could only be used to challenge the legality of a prisoner's detention, and not to challenge the merits of the underlying criminal case. The Court's decision in Alexander v. Bryan established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal custody. The decision also clarified the scope of the writ of habeas corpus, and established that it could only be used to challenge the legality of a prisoner's detention, and not to challenge the merits of the underlying criminal case.

Justice Field delivered the dissenting opinion in Alexander v. Bryan, arguing that the majority's decision was contrary to both law and justice. He argued that under existing laws, a contract between two parties could not be enforced if it violated public policy or morals; thus, he believed that contracts which were made with an intent to defraud creditors should not be enforceable either. Furthermore, Justice Field noted that while the majority had found no evidence of fraud in this particular case, there was ample evidence of bad faith on behalf of one party—the defendant—which should have been taken into consideration when deciding whether or not to enforce the contract. In conclusion, Justice Field maintained his belief that such contracts ought never be enforced by courts as they are against public policy and morality and do nothing but encourage dishonesty among citizens.