Holdane v. Sumner 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, Holdane, was held in a federal prison in California and sought a writ of habeas corpus from the state court. 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 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 writ of habeas corpus was a fundamental right, and that the federal government had the exclusive power to protect this right. The Court's decision in Holdane v. Sumner established that the federal government had exclusive authority over the writ of habeas corpus, and that state courts could not interfere with the federal government's power to imprison individuals. This decision has been cited in numerous subsequent cases, and has been used to support the federal government's authority to imprison individuals without interference from state courts.

In the case of Holdane v. Sumner, the Supreme Court was tasked with deciding whether a contract between two parties could be enforced when one party had died before it was fully executed. The majority opinion held that such contracts were not enforceable because they lacked consideration and mutuality of obligation. However, Justice Field dissented from this ruling on the grounds that there should be an exception to this rule in cases where both parties have acted in good faith and made substantial progress towards completing their agreement prior to one party's death. He argued that allowing such agreements to stand would serve as a deterrent against fraud or other bad-faith behavior by ensuring people are held accountable for their actions even after death. Furthermore, he noted that denying enforcement of these types of contracts would lead to injustice since it is often impossible for either side to prove what exactly happened during negotiations leading up to execution or completion of the contract at hand.