In Chaboya v. Umberger, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue a writ of habeas corpus to a prisoner who had been convicted in a federal court. The petitioner, Chaboya, had been convicted in a federal court of the crime of counterfeiting and sentenced to imprisonment. He then sought a writ of habeas corpus from a state court, claiming that his conviction was invalid because the federal court lacked jurisdiction. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus in this case. The Court reasoned that the writ of habeas corpus is a remedy that is available only to those who are in custody under the authority of the state, and not to those who are in custody under the authority of the federal government. The Court further held that the state court did not have the authority to review the validity of a federal court's judgment. 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 who had been convicted in a federal court. The Court reasoned that the writ of habeas corpus is a remedy that is available only to those who are in custody under the authority of the state, and not to those who are in custody under the authority of the federal government. The Court further held that the state court did not have the authority to review the validity of a federal court's judgment.

Justice Field delivered the dissenting opinion in Chaboya v. Umbarger, arguing that the majority's decision was incorrect and should be reversed. He argued that a contract between two parties is binding on both of them, regardless of whether it has been reduced to writing or not. Furthermore, he noted that there are many cases where oral contracts have been enforced by courts despite their lack of written formality. In this case specifically, Justice Field believed there was sufficient evidence to prove an agreement had been made between Chaboya and Umbarger regarding payment for goods sold; therefore, he felt the court should enforce it as such. He concluded his dissent by stating that if a party fails to perform according to its contractual obligations then they must suffer any consequences resulting from their breach without being able to use lack of formalities as an excuse for non-performance or avoidance thereof.