Grafton v. Cummings 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 held in a federal prison. The case arose when the petitioner, Grafton, was convicted of a federal crime and sentenced to imprisonment in a federal prison. Grafton then sought a writ of habeas corpus from the state court, claiming that his imprisonment was illegal. 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 convicted of federal crimes. 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 imprisonment, and not to challenge the merits of the underlying conviction. 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 convicted of federal crimes.

In Grafton v. Cummings, the Supreme Court was asked to determine whether a deed of land in Wisconsin had been validly executed and delivered by the grantor. The majority opinion held that there was sufficient evidence to establish delivery of the deed, but Justice Field dissented on this point. He argued that while it may have been possible for the grantor to deliver possession of the property through an agent or attorney-in-fact, there was no proof that such a delivery had actually occurred in this case. Furthermore, he noted that even if some form of constructive delivery could be established from circumstantial evidence, it would not be enough to satisfy all legal requirements for a valid conveyance under Wisconsin law at the time. Therefore, Justice Field concluded that without clear proof of actual physical transfer from one party to another - which did not exist here - any purported conveyance should fail as invalid and unenforceable under state law.