Barton v. Barbour 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 the state court issued a writ of habeas corpus to a prisoner held in a federal prison in the state of Mississippi. The prisoner, Barton, had been convicted of a federal crime and was serving his sentence in the federal prison. The state court argued that it had the authority to issue the writ of habeas corpus because the prisoner was held in the state. The Supreme Court held that the state court did not have the authority to issue the writ of habeas corpus. The Court reasoned that the writ of habeas corpus was a federal remedy and that the state court did not have the authority to issue it. The Court further held that the state court did not have the authority to interfere with the federal prison system. The Court concluded that the state court did not have the authority to issue the writ of habeas corpus and that the prisoner must be released from federal custody.

Justice Field delivered the dissenting opinion in Barton v. Barbour, arguing that the majority had misconstrued a key provision of the Bankruptcy Act of 1867. He argued that Congress intended to provide relief for debtors who were unable to pay their debts due to circumstances beyond their control and not those whose insolvency was caused by their own negligence or misconduct. The language used in Section 4 of the act clearly indicated this intent, as it provided protection only when "the debtor has been prevented from paying his debts" by some external force such as fire, flood, or other natural disaster. Therefore, Justice Field concluded that since there was no evidence presented at trial indicating any external cause for Mr. Barbour's inability to pay his creditors' claims against him he should not be entitled to discharge under Section 4 of the Bankruptcy Act and thus remain liable on all outstanding obligations owed prior to filing bankruptcy proceedings.