In Coffee v. Groover, 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 had been convicted in a federal court. The petitioner, Coffee, had been convicted in a federal court of violating the federal law prohibiting the sale of liquor in Indian Territory. He was sentenced to two years in prison and was subsequently transferred to a state prison. Coffee then filed a petition for a writ of habeas corpus in the state court, arguing that his conviction was invalid because the federal court lacked jurisdiction. The state court granted the writ and ordered Coffee released from prison. 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 in this case. The Court reasoned that the writ of habeas corpus is a federal remedy and can only be issued by a federal court. The Court further held that the state court lacked jurisdiction to review the validity of a federal conviction. Therefore, the state court's decision to issue the writ of habeas corpus was reversed.

Justice Field delivered the dissenting opinion in Coffee v. Groover, a case concerning the constitutionality of an act passed by the state of Georgia that allowed for writs of error to be issued from circuit courts to superior courts. Justice Field argued that this act was unconstitutional because it violated Article III and IV of the Constitution which states that only Supreme Court justices have authority over appeals from state court decisions. He further argued that allowing such writs would give too much power to lower-level judges who are not appointed or confirmed by Congress as required by Article II and thus violate separation of powers principles established in Marbury v Madison (1803). Finally, he noted how this law could lead to confusion among litigants since there is no guarantee they will receive consistent rulings on similar cases due to different interpretations given by various judges across multiple circuits.