In Cockle et al. v. Flack et al., the Supreme Court of the United States was asked to decide whether a state court had the authority to issue a writ of mandamus to a federal court. The case arose when the plaintiffs, Cockle and others, filed a petition in the Circuit Court of the United States for the District of Kansas, seeking to enjoin the defendants, Flack and others, from interfering with their possession of certain lands. The Circuit Court denied the petition, and the plaintiffs then sought a writ of mandamus from the Supreme Court of Kansas, directing the Circuit Court to issue the injunction. The Supreme Court of Kansas granted the writ, and the defendants appealed to the Supreme Court of the United States. The Supreme Court held that the Supreme Court of Kansas had no authority to issue a writ of mandamus to the Circuit Court of the United States. The Court reasoned that the Circuit Court was a court of the United States, and that the Supreme Court of Kansas was a court of the state of Kansas. As such, the Supreme Court of Kansas had no authority to issue a writ of mandamus to a court of the United States. The Court further held that the Circuit Court had the power to issue the injunction sought by the plaintiffs, and that the plaintiffs should have sought relief from the Circuit Court, rather than from the Supreme Court of Kansas.

Justice Field delivered the dissenting opinion in Cockle et al. v. Flack et al., arguing that the majority's decision was incorrect and should be reversed. He argued that Congress had no authority to pass a law allowing for an appeal from a state court judgment, as it violated both Article III of the Constitution and Section 25 of the Judiciary Act of 1789 which gave exclusive jurisdiction over appeals to this Court alone. Furthermore, he argued that even if Congress did have such power, it could not be exercised retroactively because there was no indication in either statute or common law precedent that would allow for such action. Finally, Justice Field noted that while Congress may have been able to pass laws granting rights after they were denied by state courts, they could not do so when those rights had already been granted by them; thus making any attempt at appealing these judgments unconstitutional under Article III of the Constitution and Section 25 of the Judiciary Act of 1789.