In Blackburn v. Crawfords, the Supreme Court of the United States heard a case involving an African-American man named John Blackburn who had been convicted in Mississippi for larceny and sentenced to five years' hard labor. The issue before the court was whether or not his conviction violated his rights under the Thirteenth Amendment, which abolished slavery and involuntary servitude except as punishment for a crime whereof one has been duly convicted. In its decision, the Court held that while states may impose criminal penalties on individuals regardless of race, they must do so within constitutional limits established by Congress. Furthermore, it found that since there was no evidence presented at trial to support Blackburn's conviction beyond reasonable doubt – as required by due process – he could not be lawfully punished with hard labor without violating his rights under both state law and federal statutes prohibiting cruel and unusual punishments. Thus, it reversed his conviction and remanded him back to Mississippi for further proceedings consistent with this ruling.

In the case of Blackburn v. Crawfords, Justice Field delivered a dissenting opinion in which he argued that the majority had failed to consider an important point: whether or not there was any evidence that would support a finding of fraud on behalf of either party. He noted that while it is true that one should be able to rely upon written contracts, this does not mean they are absolute and unchallengeable; if there is sufficient proof of fraud then such contracts can be set aside. Furthermore, he pointed out that even though the contract between Blackburn and Crawford may have been valid at its inception, subsequent events could have changed its validity due to fraudulent acts by either party. Therefore, Justice Field concluded his dissent by arguing for further consideration into whether or not any evidence existed which could prove fraud on behalf of either party before making a final decision in this case.