Clough v. Barker 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, Clough, was held in a federal prison in Massachusetts. Clough 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 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 remedy, and that the state court did not have the power to interfere with the federal government's authority to imprison individuals. The Court also noted that the writ of habeas corpus was a remedy that could only be used to challenge the legality of a person's detention, and not to challenge the conditions of the detention. The Court's decision in Clough v. Barker established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons. This decision has been cited in numerous subsequent cases, and has been used to support the principle that state courts cannot interfere with the federal government's authority to imprison individuals.

Justice Field delivered the dissenting opinion in Clough v. Barker, a case involving an appeal from the Circuit Court of the United States for the District of Massachusetts. The majority held that a contract between two parties was invalid because it had not been executed according to state law and thus could not be enforced by either party. Justice Field disagreed with this ruling, arguing that since both parties had agreed to its terms and conditions, they should be bound by them regardless of any technicalities regarding execution under state law. He further argued that if one party were allowed to escape liability due to such technicalities while still receiving benefits from their agreement with another party, then contracts would become meaningless as no one would have any incentive or assurance that their agreements will be honored in court. As such, he concluded his dissent by stating his belief that courts should enforce contracts when there is evidence of mutual assent between two parties even if those contracts are technically invalid under state laws governing execution requirements