Hodge v. Combs was a case heard by the United States Supreme Court in 1861. The dispute arose when William Hodge, an African American man, sued his former master, John Combs for breach of contract and false imprisonment. Hodge had been hired as a farm laborer by Combs with the understanding that he would be paid wages at the end of his term of service; however, upon completion of his work he was not given any compensation or allowed to leave without being arrested and imprisoned on charges related to vagrancy laws. In its ruling on this case, the Supreme Court held that although slavery had been abolished in Kentucky (where this incident occurred), it did not necessarily follow that all persons were free from arrest under state vagrancy laws unless they could prove their freedom through some other means such as written proof or testimony from witnesses who knew them personally prior to emancipation. Furthermore, since there was no evidence presented showing that Hodge had ever entered into any kind of contractual agreement with Combs regarding payment for labor performed while employed by him - nor any proof indicating otherwise - then it must be assumed that no such arrangement existed between them and thus no legal basis existed for either party's claims against one another in court proceedings

In Hodge v. Combs, the Supreme Court was asked to decide whether a state court had jurisdiction over a case involving an Indian tribe and non-Indians. The majority opinion held that the state courts did not have jurisdiction in this matter because it involved members of an Indian tribe who were under federal protection. However, Justice Grier dissented from this decision on the grounds that Congress had never expressly prohibited states from exercising their authority over such matters and therefore they should be allowed to do so. He argued that if Congress wanted to limit or deny states' power in these cases, it would have done so explicitly through legislation or treaty making powers granted by the Constitution. Furthermore, he noted that allowing states to exercise their own legal authority could help protect Indians against frauds perpetrated by non-Indians as well as provide them with access to justice when disputes arise between tribes and other parties outside of tribal governments’ control.