In Ashby v. Hall, the United States Supreme Court was asked to decide whether a state court had jurisdiction to hear a case involving a dispute between two citizens of different states. The plaintiff, Ashby, was a citizen of Virginia and the defendant, Hall, was a citizen of North Carolina. Ashby had brought a suit against Hall in a Virginia court, alleging that Hall had wrongfully taken possession of a piece of property in Virginia that belonged to Ashby. Hall argued that the Virginia court did not have jurisdiction to hear the case because he was a citizen of North Carolina. The Supreme Court held that the Virginia court did have jurisdiction to hear the case. The Court reasoned that the Constitution of the United States gave the federal government the power to regulate interstate commerce, and that this power included the power to regulate disputes between citizens of different states. The Court further reasoned that the Virginia court had the power to hear the case because the dispute involved a piece of property located in Virginia. The Court concluded that the Virginia court had jurisdiction to hear the case and that Ashby was entitled to a judgment against Hall. The Court also held that the Virginia court had the power to enforce the judgment against Hall, even though he was a citizen of North Carolina.

Justice Field delivered the dissenting opinion in Ashby v. Hall, arguing that the majority had misinterpreted a key provision of the Civil Rights Act of 1875. He argued that Congress had intended to protect all persons from discrimination based on race or color, regardless of whether they were citizens or not. The majority opinion held that only citizens could bring suit under this act; however, Justice Field believed this interpretation was too narrow and would lead to unequal protection for non-citizens who faced racial discrimination. He further noted that if Congress had wanted to limit suits brought under this act solely to citizens it would have done so explicitly in its language rather than leaving such an important issue open for debate and interpretation by courts. Ultimately he concluded his dissent by stating "The right is one which should be enjoyed alike by every human being within our borders."