Benziger v. Robertson was a United States Supreme Court case that dealt with the issue of whether a state court had the authority to issue a writ of habeas corpus to a prisoner who was being held in a federal prison. The case arose when a prisoner, John Benziger, was held in a federal prison in California. Benziger sought a writ of habeas corpus from the California Supreme Court, claiming that he was being held in violation of the Constitution. The California Supreme Court granted the writ, and the United States Supreme Court was asked to decide whether the state court had the authority to do so. 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 power to issue such a writ. The Court also noted that the writ of habeas corpus was a remedy that could only be used in cases where the prisoner was being held in violation of the Constitution. Since Benziger was being held in a federal prison, the Court held that the state court did not have the authority to issue the writ.

Justice Field delivered the dissenting opinion in Benziger v. Robertson, arguing that the Court should not have reversed the decision of the Supreme Court of California. He argued that while it was true that a contract had been made between Benziger and Robertson, there were other facts which needed to be considered before determining whether or not this contract was valid under California law. Specifically, he noted that when Benziger sold his land to Robertson, he did so with an understanding that certain improvements would be made by both parties; however, these improvements were never completed as promised by either party. Furthermore, Justice Field argued that since no consideration had been given for these promises on either side - meaning neither party gave anything up in exchange for them - they could not form part of any legally binding agreement between them and thus could not be enforced in court. As such, Justice Field concluded it was wrong for the Court to reverse the decision of lower courts without taking into account all relevant facts surrounding this case and its underlying contracts.