Bates v. Clark was a United States Supreme Court case that dealt with the issue of whether a state court had the authority to issue an injunction against a federal court. The case arose when the state of Arkansas issued an injunction against the federal court in the Western District of Arkansas, preventing it from hearing a case involving a dispute between two parties. The Supreme Court held that the state court did not have the authority to issue such an injunction, as it was in violation of the Supremacy Clause of the United States Constitution. The Court reasoned that the state court was attempting to interfere with the federal court's jurisdiction, which was prohibited by the Constitution. The Court also held that the state court's injunction was void, as it was in violation of the Constitution. The Court further held that the federal court had the authority to proceed with the case, and that the state court's injunction was not binding.

Justice Field delivered the dissenting opinion in Bates v. Clark, a case concerning the validity of a deed executed by an Indian tribe to private individuals. Justice Field argued that Congress had exclusive authority over Indian tribes and their lands, and thus any sale or transfer of land must be approved by Congress before it can be considered valid. He noted that while some treaties between Indians and settlers may have allowed for such transfers without congressional approval, this particular treaty did not contain such language; therefore, he concluded that the deed was invalid as it had not been authorized by Congress. Furthermore, Justice Field asserted that even if there were provisions allowing for sales without congressional approval in other treaties with different tribes, those provisions would still need to be ratified by Congress before they could take effect on this particular tribe's lands. In conclusion, Justice Field maintained his position that only acts of congress could authorize land transfers from Native American tribes to private citizens.