In Burbank v. Bigelow et al., the United States Supreme Court was asked to decide 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, Burbank, was held in a federal prison in Massachusetts. He sought a writ of habeas corpus from the state court, claiming that he was being held in violation of the Constitution. The state court granted the writ, and the federal government appealed to the Supreme Court. 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 power, 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 interfere with the federal government's power to protect this right. The Court's decision in Burbank v. Bigelow et al. established 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 decision also established that the writ of habeas corpus was a fundamental right that the federal government had the power to protect.

Justice Field delivered the dissenting opinion in Burbank v. Bigelow et al., arguing that the majority's decision was contrary to both common law and equity principles. He argued that a contract between two parties should be enforced according to its terms, regardless of whether it is fair or not. Furthermore, he stated that if one party has been injured by another's breach of contract, they are entitled to compensation for their losses as long as there is no evidence of fraud or mistake on either side. In this case, Justice Field believed that Bigelow had breached his agreement with Burbank and thus owed him damages for any loss suffered due to such breach. As such, he concluded that the lower court's ruling should have been affirmed instead of reversed by the Supreme Court majority opinion.