Gould v. Rees was a United States Supreme Court case that addressed the issue of whether a state court had the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The case arose when a prisoner, William Gould, was held in a federal prison in California. Gould sought a writ of habeas corpus from the California Supreme Court, which was denied. Gould then appealed to the United States Supreme Court. The Supreme Court held that the California Supreme 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 prerogative, 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 fundamental right, and that the state court should not be allowed to interfere with the federal government's power to imprison individuals. In conclusion, the Supreme Court held that the California Supreme 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 prerogative, 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 fundamental right, and that the state court should not be allowed to interfere with the federal government's power to imprison individuals.

Justice Field delivered the dissenting opinion in Gould v. Rees, arguing that the majority's decision was contrary to established law and precedent. He argued that a contract between two parties should be enforced according to its terms unless it is found to be invalid or unenforceable by some other legal principle. In this case, he believed that there was no evidence of fraud or mistake on either side which would have rendered the contract voidable; thus, it should have been enforced as written. Furthermore, Justice Field noted that if one party were allowed to unilaterally change their obligations under a contract without any valid reason for doing so then contracts could not serve their purpose as an effective means of securing mutual promises and agreements between individuals. As such, he concluded that the lower court's ruling should have been affirmed instead of reversed by the Supreme Court majority opinion.