Fox v. Seal 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, John Seal, was held in a federal prison in Louisiana. Seal sought a writ of habeas corpus from the state court, claiming that he was being held in violation of the Constitution. 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 power to interfere with the federal government's authority 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 person's detention, and not to challenge the conditions of the detention. In conclusion, 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 power to interfere with the federal government's authority to imprison individuals.

Justice Field delivered the dissenting opinion in Fox v. Seal, arguing that the majority had failed to consider a key point of law: whether or not an individual has a right to sue for damages when their property is taken without due process of law. He argued that this was an issue which should have been addressed by the court and not simply dismissed as irrelevant. Furthermore, he noted that if individuals do indeed possess such a right then it would be unconstitutional for any state government to deny them access to legal remedies in order to protect their rights from being violated by another party. In conclusion, Justice Field asserted that while he agreed with much of what was said in the majority opinion, he felt strongly that they had overlooked this important aspect of constitutional law and thus his dissent remained unchanged despite its minority status on this case.