In Hartranft v. Sheppard, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue a writ of habeas corpus to a prisoner who had been convicted in a federal court. The petitioner, Hartranft, had been convicted in a federal court of a crime and was serving his sentence in a state prison. He then filed a petition for a writ of habeas corpus in the state court, claiming that his conviction was unconstitutional. The state court granted the writ and ordered the prisoner released. 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 is a federal remedy and that the state court did not have the power to interfere with a federal conviction. The Court also noted that the writ of habeas corpus is a remedy of last resort and should only be used when all other remedies have been exhausted. The Court concluded that the state court did not have the authority to issue the writ of habeas corpus and that the prisoner must remain in custody. The Court also noted that the prisoner could still seek relief from the federal court.

Justice Field delivered the dissenting opinion in Hartranft v. Sheppard, arguing that the majority had misapplied the law and failed to consider all of its implications. He argued that under Pennsylvania state law, a contract was formed when an offer was accepted by both parties and consideration exchanged. In this case, he believed there had been such an agreement between Hartranft and Sheppard: Hartranft offered to pay $2 per acre for land owned by Sheppard; Sheppard accepted; they agreed on terms of payment; and each party gave something in exchange (Hartranft paid money while Sheppard conveyed title). Therefore, Justice Field concluded that a valid contract existed between them which should have been enforced according to its terms.