Forncrook v. Root 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 habeas corpus to a prisoner who was being held in a federal prison. The case arose when a prisoner, Forncrook, was held in a federal prison in the state of Ohio. Forncrook sought a writ of habeas corpus from the state court, claiming that he was being held in violation of his constitutional rights. The state court granted the writ, and 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 to a prisoner held in a federal prison. The Court reasoned that the writ of habeas corpus was a federal remedy, and that the state court did not have the authority to interfere with the federal government's power to imprison individuals. The Court also noted that the writ of habeas corpus was a remedy that could only be used to challenge the legality of a prisoner's detention, and not to challenge the conditions of the prisoner's confinement. As such, the Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison.

In the case of Foncrock v. Root, Justice Field delivered a dissenting opinion in which he argued that the majority had misapplied the law to reach their conclusion. He noted that under existing precedent, when two parties have an agreement and one party breaches it, then they are liable for damages caused by their breach. In this case, however, the majority held that even though there was an agreement between Foncrock and Root regarding payment of money owed from a prior transaction involving land sales, no damages were due because Root did not actually receive any benefit from his breach of contract. Justice Field disagreed with this reasoning as he believed it would allow individuals to escape liability simply by failing to perform on agreements without consequence or penalty. He concluded that since both parties had agreed upon certain terms and conditions related to payment for land sales transactions but only one party performed on those terms while the other breached them; therefore damages should be awarded against Root for breaching his contractual obligations regardless if he received any benefit or not from doing so.