In Bayard v. United States ex rel. White, the Supreme Court of the United States was asked to decide whether a private citizen could bring a suit against the United States on behalf of another private citizen. The case involved a dispute between two private citizens, Bayard and White, over a contract for the sale of a steamboat. White had sued Bayard in a state court, but the case was dismissed because the contract was made with the United States. White then brought a suit against the United States in the Court of Claims, seeking to recover the money he was owed under the contract. The Supreme Court held that a private citizen could not bring a suit against the United States on behalf of another private citizen. The Court reasoned that the United States was not a party to the contract between Bayard and White, and thus had no obligation to enforce it. The Court also noted that the United States had not waived its sovereign immunity, and thus could not be sued by a private citizen. The Court's decision in Bayard v. United States ex rel. White established that a private citizen cannot bring a suit against the United States on behalf of another private citizen. This decision has been cited in numerous subsequent cases, and remains an important precedent in the area of sovereign immunity.

In Bayard v. United States ex rel. White, the Supreme Court was tasked with determining whether a writ of mandamus should be issued to compel the Secretary of War to issue a commission for an officer in the Army who had been appointed by President Cleveland but not yet commissioned. Justice Field delivered a dissenting opinion, arguing that Congress did not have authority under Article II of the Constitution to vest such power in any other person than the President himself and that it would be unconstitutional for Congress to delegate this power away from him. He further argued that if Congress could do so, then they would also have authority over all executive appointments made by presidents and thus undermine their constitutional powers as Commander-in-Chief of military forces. As such, he concluded that no writ should be issued since there was no legal basis upon which one could be granted given these circumstances.