Brown v. Spofford 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, William Brown, was held in a federal prison in New York. Brown sought a writ of habeas corpus from the state court, claiming that he was being held in violation of his constitutional rights. The state court granted the writ, and the federal government appealed the decision to the Supreme Court. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The Court reasoned that the writ of habeas corpus was a federal prerogative, and that the state court did not have the authority to interfere with the federal government's power to imprison individuals. The Court also noted that the writ of habeas corpus was a fundamental right, and that the state court should not be allowed to interfere with the federal government's power to protect the rights of individuals. In conclusion, the Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The Court reasoned that the writ of habeas corpus was a federal prerogative, and that the state court did not have the authority to interfere with the federal government's power to imprison individuals. The Court also noted that the writ of habeas corpus was a fundamental right, and that the state court should not be allowed to interfere with the federal government's power to protect the rights of individuals.

Justice Field delivered the dissenting opinion in Brown v. Spofford, arguing that the majority's decision was wrongfully based on a misreading of the relevant statute. He argued that under New York law, when an executor is appointed to administer an estate and has possession of property belonging to it, he or she holds title as trustee for those entitled to share in its distribution. In this case, Spofford had been appointed by a court order as executor and administrator of his father's estate; thus any property held by him belonged not to him but rather was held in trust for all who were entitled to receive distributions from it. Justice Field concluded that since there had been no transfer or conveyance of title from Spofford back into his own name prior to Brown's purchase at auction, Brown could not have acquired good title through such purchase because Spofford did not possess legal authority over it at the time.