In Freeland v. Williams, the United States Supreme Court addressed the issue of whether a state court could enjoin a federal court from hearing a case. The plaintiff, Freeland, had filed a suit in a federal court against the defendant, Williams, for the collection of a debt. Williams then filed a suit in a state court seeking an injunction to prevent the federal court from hearing the case. The Supreme Court held that the state court did not have the authority to enjoin the federal court from hearing the case. The Court reasoned that the state court was not a court of competent jurisdiction to enjoin the federal court, and that the state court's action was an interference with the federal court's jurisdiction. The Court further held that the state court's action was an unconstitutional interference with the federal court's jurisdiction, and that the injunction should be dissolved. The Court concluded that the state court had no authority to enjoin the federal court from hearing the case.

In Freeland v. Williams, the Supreme Court was asked to decide whether a contract between two parties that had been partially performed could be enforced in court. The majority opinion held that it could not, as the statute of frauds required all contracts for land sales to be in writing and signed by both parties. Justice Field dissented from this decision, arguing that since part of the agreement had already been completed (the payment of money), there should have been an exception made for this case under equity principles. He argued that if one party has substantially complied with their obligations under a contract then they should still be able to enforce it even if certain formalities are missing or incomplete; otherwise people would suffer unjustly due to technicalities rather than any real wrongdoing on their part.