Dows & Another v. Johnson 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 compel a county auditor to issue a tax deed. The Supreme Court held that the state court did not have the authority to issue such a writ. The case arose when the plaintiffs, Dows & Another, purchased a tract of land in Iowa from the county auditor. The auditor refused to issue a tax deed for the property, and the plaintiffs sought a writ of mandamus from the state court to compel the auditor to issue the deed. The state court granted the writ, and the auditor appealed to the Supreme Court. The Supreme Court held that the state court did not have the authority to issue the writ of mandamus. The Court reasoned that the writ of mandamus was a judicial remedy, and the state court did not have the authority to issue such a remedy against a county auditor. The Court further held that the state court could not issue a writ of mandamus to compel the auditor to perform a ministerial duty. In conclusion, the Supreme Court held that the state court did not have the authority to issue a writ of mandamus to compel the county auditor to issue a tax deed. The Court reasoned that the writ of mandamus was a judicial remedy, and the state court did not have the authority to issue such a remedy against a county auditor.

Justice Field delivered the dissenting opinion in Dows & Another v. Johnson, arguing that the majority's decision was contrary to both law and equity. He argued that under Illinois state law, a contract for sale of land could not be enforced unless it was in writing or evidenced by some memorandum signed by the party against whom enforcement is sought. In this case, there had been no such written agreement between plaintiff and defendant; instead, they had only entered into an oral agreement which did not meet the requirements set out in Illinois state law. Furthermore, Justice Field noted that even if there were evidence of a valid contract between them, it would still be unenforceable due to its lack of consideration - meaning neither party provided anything valuable to each other as part of their bargain. As such he concluded that plaintiffs' claim should have been dismissed on these grounds alone without any need for further inquiry into matters outside the scope of their complaint.