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Heald v. Rice 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 a prisoner, Heald, was held in a federal prison in the state of New York. Heald sought a writ of habeas corpus from the state court, claiming that he was being held in violation of his constitutional rights. 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. 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 detention, and not to challenge the merits of the underlying criminal charge. The Court's decision in Heald v. Rice established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons. This decision has been cited in numerous subsequent cases, and remains an important precedent in the area of federal-state relations.
Justice Field delivered the dissenting opinion in Heald v. Rice, arguing that the majority's decision was contrary to both precedent and common sense. The case concerned a dispute between two parties over an unpaid debt of $2,000 plus interest accrued since 1859. The lower court had ruled in favor of the plaintiff on summary judgment but this ruling was reversed by the Supreme Court on appeal due to a lack of evidence as to when exactly interest began accruing on the debt. Justice Field argued that it should have been assumed from all available facts that interest had begun accruing at least six years prior and thus there should have been sufficient evidence for summary judgment against defendant Rice without further inquiry into exact dates or amounts owed. Furthermore, he noted that such an interpretation would be consistent with established legal principles which presume payment of debts unless proven otherwise by clear and convincing evidence; here no such proof existed so it seemed reasonable to assume payment had occurred according to terms agreed upon by both parties at some point before suit was filed. In conclusion, Justice Field concluded his dissent stating “I am unable...to concur in reversing [the] decree” given what appeared obvious from all available facts: namely, that plaintiff Heald deserved compensation for his losses incurred due to defendant Rice's failure pay back money owed him many years ago