Bartram v. Robertson was a United States Supreme Court case that addressed the issue of whether a state court could modify a foreclosure decree. The case involved a dispute between two parties, Bartram and Robertson, over a mortgage foreclosure. Bartram had obtained a foreclosure decree from a state court, but Robertson argued that the decree should be modified to allow him to redeem the property. The Supreme Court held that the state court had the authority to modify the foreclosure decree, as long as the modification was consistent with the state's foreclosure laws. The Court also held that the state court had the power to modify the decree in order to protect the rights of the mortgagor. The Court's decision established that state courts have the authority to modify foreclosure decrees in order to protect the rights of the mortgagor. This decision has been cited in numerous subsequent cases involving foreclosure decrees.

Justice Field delivered the dissenting opinion in Bartram v. Robertson, arguing that a state court should not be able to review and reverse a decision of the federal courts. He argued that this would undermine the authority of the federal judiciary and create confusion between state and federal law. Furthermore, he noted that allowing such reviews could lead to conflicting decisions from different courts on similar cases. Justice Field also pointed out that if states were allowed to review decisions made by federal courts, it would give them too much power over matters which are supposed to be decided by Congress or other branches of government. Finally, he argued that granting states such powers could potentially lead to an erosion of civil liberties as well as weaken judicial independence in general.