In Garfield v. Paris, the United States Supreme Court was asked to decide 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 petitioner, Garfield, was a prisoner in the federal penitentiary in Leavenworth, Kansas. He had been convicted of a federal crime and was serving a sentence of five years. He sought a writ of habeas corpus from the state court in order to challenge the legality of his confinement. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner in a federal prison. The Court reasoned that the power to issue a writ of habeas corpus was a power reserved to the federal government, and that the state court did not have the authority to interfere with the federal government's power to imprison a person convicted of a federal crime. The Court also noted that the state court had no jurisdiction over the federal prison, and thus could not issue a writ of habeas corpus. 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 in a federal prison. The Court reasoned that the power to issue a writ of habeas corpus was a power reserved to the federal government, and that the state court did not have the authority to interfere with the federal government's power to imprison a person convicted of a federal crime.

Justice Field delivered the dissenting opinion in Garfield v. Paris, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that a contract between two parties is binding upon them both, regardless of any subsequent changes to state laws or regulations. In this case, he believed that when Mr. Garfield entered into an agreement with Mrs. Paris for her to pay him $2 per acre for his land at a certain price and on certain terms, it created an obligation which could not be affected by later legislation passed by Congress or other authorities in California where the property was located; thus making it impossible for Mrs. Paris to avoid paying what she had agreed to pay under their contract without being held liable for damages due to breach of contract if she failed do so as promised in their agreement.. Justice Field concluded his dissent by stating that while he did not agree with all parts of the majority opinion, he felt strongly enough about this particular point - namely upholding contracts made between private individuals -that he felt compelled to issue a separate dissenting opinion on this matter alone