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Field v. De Comeau & Another

• 1885 • 116 U.S. 187 • Waite Court
Field v. De Comeau & Another was a United States Supreme Court case that addressed the issue of whether a state court had the authority to issue a writ of habeas corpus to a person who was being held in another state. The case involved a man named Field who was arrested in Massachusetts and held in custody in New York. Field filed a petition for a writ of habeas corpus in the Massachusetts court, arguing that he was being unlawfully detained in New York. The Massachusetts court granted the writ...Open Case
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Chief Waite Court
Term: 1885
Docket: 84
116 U.S. 187
6 S. Ct. 363
29 L. Ed. 596
1886 U.S. LEXIS 1749

Field v. De Comeau & Another

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Opinion Summary
AI Abstract

Field v. De Comeau & Another was a United States Supreme Court case that addressed the issue of whether a state court had the authority to issue a writ of habeas corpus to a person who was being held in another state. The case involved a man named Field who was arrested in Massachusetts and held in custody in New York. Field filed a petition for a writ of habeas corpus in the Massachusetts court, arguing that he was being unlawfully detained in New York. The Massachusetts court granted the writ and ordered Field to be released from custody in New York. The Supreme Court held that the Massachusetts court did not have the authority to issue the writ of habeas corpus. The Court reasoned that the writ of habeas corpus was a judicial remedy that could only be issued by a court of the state in which the person was being held. The Court further held that the writ of habeas corpus could not be issued by a court of another state. Therefore, the Massachusetts court did not have the authority to issue the writ of habeas corpus and Field was not entitled to be released from custody in New York.

Dissent Summary
AI Abstract

In Field v. De Comeau & Another, the Supreme Court was tasked with determining whether a contract between two parties in Massachusetts that involved land located in Maine could be enforced by a court of law. The majority opinion held that such contracts were not enforceable due to the Full Faith and Credit Clause of the Constitution which requires states to respect laws made by other states. Justice Miller dissented from this decision, arguing that since both parties had voluntarily entered into an agreement regarding property situated in another state, it should be respected and enforced as valid under common law principles regardless of any constitutional considerations. He further argued that if one party failed to fulfill their obligations under the contract then they should face legal consequences for breach of contract just like any other situation where someone fails to uphold their end of an agreement.

Opinion written by Justice SMatthews
Decided: Jan 04, 1886
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