Cutler v. Kouns & Another 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 mandamus to a federal court. The case arose when the plaintiff, Cutler, sought to have the state court issue a writ of mandamus to the federal court to compel the latter to issue a writ of habeas corpus. The Supreme Court held that the state court did not have the authority to issue a writ of mandamus to a federal court. The Court reasoned that the state court lacked the power to issue a writ of mandamus to a federal court because the federal court was a court of exclusive jurisdiction. The Court further held that the state court could not interfere with the proceedings of the federal court. The Court concluded that the state court lacked the authority to issue a writ of mandamus to the federal court and that the writ of mandamus was properly denied.

Justice Field delivered the dissenting opinion in Cutler v. Kouns & Another, arguing that the majority's decision was contrary to established precedent and would lead to an unjust result. He argued that under prior decisions of the Supreme Court, a judgment creditor could not be denied access to property held by a third party if it had been acquired with funds from the debtor after entry of judgment against them. The majority had found otherwise, ruling that because there was no evidence showing when exactly Kouns received his payment from Cutler, he should be allowed to retain possession of it until such time as proof is provided demonstrating its origin. Justice Field disagreed with this conclusion and instead argued for strict adherence to existing law which states that once a debt has been entered into judgment, any subsequent payments made by the debtor are subject immediately upon receipt by their creditors regardless of whether or not they can prove when those payments were actually made. In doing so he maintained that allowing Kouns' claim would create an unfair situation where debtors could avoid paying judgments simply by transferring money through intermediaries who have no knowledge or interest in their legal proceedings; thus creating an incentive for fraud and injustice rather than justice being served as intended under current laws governing these matters.