In County Court of Lincoln County and the Judges Thereof v. United States, Ex Rel. Vespasian Warner, the Supreme Court of the United States was asked to decide whether a writ of mandamus could be issued to compel the judges of the County Court of Lincoln County to issue a writ of habeas corpus. The case arose when Vespasian Warner, a prisoner in the custody of the sheriff of Lincoln County, sought a writ of habeas corpus from the County Court of Lincoln County. The judges of the court refused to issue the writ, and Warner sought a writ of mandamus from the Supreme Court of the United States to compel the judges to issue the writ. The Supreme Court held that the writ of mandamus could not be issued because the judges of the County Court of Lincoln County were not officers of the United States, and thus the Supreme Court did not have jurisdiction to issue the writ. The Court further held that the writ of habeas corpus was a matter of state law, and thus the Supreme Court did not have jurisdiction to issue the writ. The Court concluded that the writ of mandamus could not be issued to compel the judges of the County Court of Lincoln County to issue the writ of habeas corpus.

In the dissenting opinion of County Court of Lincoln County and the Judges Thereof v. United States, Ex Rel. Vespasian Warner, Justice Field argued that Congress did not have authority to pass a law allowing citizens to sue state judges in federal court for violations of civil rights under 42 U.S.C § 1983 (1871). He believed that this was an unconstitutional exercise of power by Congress because it violated the 10th Amendment which reserves all powers not delegated to the federal government or prohibited from states as belonging solely to them. Furthermore, he argued that if such suits were allowed then it would be impossible for state courts and officers to perform their duties without fear or favor since they could always be subjecting themselves to suit in federal court at any time regardless of how well-intentioned their actions may have been. Finally, he concluded by stating that while there is no doubt some instances where individuals should receive compensation when wrongfully deprived of their constitutional rights; these cases should instead be handled through existing remedies provided by state laws rather than creating new ones via congressional legislation which violates both separation-of-powers principles and individual sovereignty over each respective state's jurisdiction