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Hampton, Administrator, & Others v. Phipps was a United States Supreme Court case that dealt with the issue of whether a state court had the authority to grant a new trial in a case that had already been decided by a federal court. The case involved a dispute between two parties over a contract for the sale of land. The state court had granted a new trial to the defendant, Phipps, on the grounds that the jury had been improperly instructed. The Supreme Court held that the state court did not have the authority to grant a new trial in a case that had already been decided by a federal court. The Court reasoned that the state court was bound by the decision of the federal court and could not grant a new trial. The Court also held that the state court was not authorized to review the jury instructions in the case. The Court concluded that the state court had exceeded its authority in granting a new trial and that the decision of the federal court should stand.
In the case of Hampton, Administrator, & Others v. Phipps (1883), Justice Field delivered a dissenting opinion in which he argued that the majority had erred in their interpretation of an 1876 Act of Congress concerning land grants to railroads. He asserted that the majority's decision was contrary to both the letter and spirit of this act and would lead to unjust results for those who were granted lands by it. Furthermore, he contended that if Congress intended for such a result they would have expressed it more clearly than what was written in this act. In conclusion, Justice Field believed that any ambiguity should be resolved against taking away rights from individuals rather than granting them additional ones as proposed by the majority’s ruling.