Andrews v. Hovey was a United States Supreme Court case that addressed the issue of whether a state court had the authority to modify a contract that had been made in another state. The case involved a contract between two parties, Andrews and Hovey, that was made in the state of Massachusetts. The contract stated that Hovey would pay Andrews a certain amount of money in exchange for certain services. However, Hovey failed to pay Andrews the full amount that was due. Andrews then sued Hovey in a Massachusetts court, and the court ruled in favor of Andrews. Hovey then appealed the decision to the Supreme Court of the United States, arguing that the Massachusetts court did not have the authority to modify the contract because it was made in another state. The Supreme Court disagreed, ruling that the Massachusetts court did have the authority to modify the contract. The Court reasoned that the contract was made in Massachusetts, and thus the state court had the authority to modify it. The Court also noted that the contract was not governed by the laws of any other state, and thus the Massachusetts court was the proper forum for the dispute. In conclusion, the Supreme Court ruled that the Massachusetts court had the authority to modify the contract between Andrews and Hovey, and that the contract was not governed by the laws of any other state. This ruling established that state courts have the authority to modify contracts that are made in their own state, even if the parties involved are from different states.

Justice Field delivered the dissenting opinion in Andrews v. Hovey, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that under California law, a married woman had no right to convey property without her husband's consent or signature; therefore, Mrs. Hovey could not have conveyed title of the property in question to Mr. Andrews as she did not possess such authority from her husband at the time of sale. Furthermore, Justice Field noted that even if Mrs. Hovey had been able to convey title on behalf of herself and her husband jointly (which he believed was impossible), it would still be invalid due to lack of consideration paid for said transfer - which is required by California law for any valid deed transfer between two parties regardless if one party is a married woman with an absent spouse or otherwise unmarried individual who can legally act alone when conveying real estate titles/interests . In conclusion, Justice Field concluded that since there was no valid deed transferring ownership rights from Mrs. Hovey and Mr. Andrews failed to pay adequate consideration for said transfer - his claim must fail as a matter of law according court precedent established by prior decisions rendered within this jurisdiction