Hartell v. Tilghman 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 who was being held in a federal prison. The case arose when a prisoner, Hartell, was held in a federal prison in Maryland. Hartell sought a writ of habeas corpus from the state court in Maryland, but the state court refused to issue the writ. Hartell then appealed to the Supreme Court, arguing that the state court had the authority to issue the writ. The Supreme Court held that the state court did not have the authority to issue the writ of habeas corpus. 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 state court had no jurisdiction over the federal prison, and thus could not issue the writ. 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 prerogative, and that the state court had no jurisdiction over the federal prison. As such, the state court could not issue the writ.

Justice Field delivered the dissenting opinion in Hartell v. Tilghman, arguing that the majority had misapplied the law and failed to consider certain facts of the case. He argued that under California law, a contract was formed when both parties agreed on its terms and conditions; however, in this case there was no agreement between Hartell and Tilghman as to how much money should be paid for services rendered by Hartell. Furthermore, Justice Field noted that even if an implied contract existed between them, it would not have been binding since it lacked consideration from either party. Finally, he pointed out that while Tilghman may have acted wrongfully by failing to pay what he owed Hartell for his services rendered over several years' time period; nonetheless such action did not constitute fraud or deceit which could give rise to damages beyond those provided by a breach of contract claim.