Andreae v. Redfield was a United States Supreme Court case that dealt with the issue of whether a contract between two parties was valid. The case involved a contract between the plaintiff, Andreae, and the defendant, Redfield, for the sale of a piece of land. Andreae had agreed to pay Redfield $2,000 for the land, and Redfield had agreed to deliver the deed to the land to Andreae. However, Redfield failed to deliver the deed, and Andreae sued for breach of contract. The Supreme Court held that the contract between the two parties was valid and enforceable. The Court noted that the contract was supported by consideration, as Andreae had agreed to pay $2,000 for the land, and Redfield had agreed to deliver the deed. The Court also noted that the contract was not void for lack of consideration, as Andreae had already paid the $2,000 to Redfield. The Court concluded that Redfield had breached the contract by failing to deliver the deed, and that Andreae was entitled to damages for the breach.

Justice Field delivered the dissenting opinion in Andreae v. Redfield, arguing that the majority had misinterpreted a key provision of the 1866 Civil Rights Act. He argued that Congress did not intend to grant citizenship to those born abroad and then naturalized by their father after birth, as was the case with plaintiff Charles Andreae. According to Justice Field, if Congress had intended for such individuals to be granted citizenship it would have explicitly stated so in its legislation; instead they chose only to provide for persons "born in" or "naturalized" within United States territory. Furthermore, he noted that this interpretation was consistent with other laws passed at around the same time which clearly distinguished between those born abroad and naturalized from those who were native-born citizens of foreign countries but later became U.S citizens through naturalization proceedings conducted on American soil. In conclusion, Justice Field asserted that allowing someone like Charles Andreae—who was never actually present on U.S soil—to become a citizen would set an undesirable precedent and undermine congressional intent when passing civil rights legislation meant specifically for native-born Americans or immigrants who underwent proper legal processes while residing within U.S borders