In Freeborn v. Smith, the Supreme Court held that a state court could not issue an injunction to prevent a federal officer from performing his duties under the Fugitive Slave Act of 1850. The case arose when William Freeborn, a deputy marshal in Wisconsin, attempted to arrest and return an escaped slave named John Smith pursuant to the act. The Wisconsin Circuit Court issued an injunction prohibiting him from doing so on grounds that it was unconstitutional for Congress to pass such legislation. However, the Supreme Court reversed this decision and ruled that only Congress had authority over matters concerning slavery and interstate commerce; thus, any attempt by states or their courts to interfere with these powers was invalid. Furthermore, since enforcing laws passed by Congress is part of a federal officer's job description they were immune from being enjoined by state courts while carrying out those duties.

In Freeborn v. Smith, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a citizen of one state against another in which the defendant resided in yet another state. The majority opinion held that it did not have such jurisdiction and dismissed the case. However, Justice Field dissented from this decision on two grounds: firstly, he argued that under Article III of the Constitution, Congress has power to regulate matters involving citizens of different states; secondly, he argued that if Congress had not exercised its authority in this regard then each State should be allowed to exercise its own discretion as long as it does not conflict with any federal law or treaty. In conclusion, Justice Field believed that since no federal statute or treaty prohibited such actions between citizens of different states then there was nothing preventing a State from exercising their right to grant jurisdiction over them.