In Holden v. Joy, the United States Supreme Court was asked to decide whether a contract between two parties was valid and enforceable. The contract in question was between the plaintiff, Holden, and the defendant, Joy. Holden had agreed to sell Joy a parcel of land for a certain sum of money. Joy had paid the agreed-upon sum, but Holden refused to convey the land. Joy then sued Holden for breach of contract. The Supreme Court held that the contract was valid and enforceable. The Court noted that the parties had agreed to the terms of the contract and that Joy had paid the agreed-upon sum. The Court also noted that the contract was not voidable due to any fraud or misrepresentation on the part of Holden. Therefore, the Court held that Joy was entitled to specific performance of the contract and that Holden was obligated to convey the land to Joy.

Justice Field delivered the dissenting opinion in Holden v. Joy, arguing that the majority's decision was contrary to established legal principles and precedent. He argued that a contract for labor is not an ordinary debt, but rather one of personal service which cannot be assigned or transferred without consent from both parties. The Court had previously held in similar cases that such contracts are non-assignable unless there is clear language indicating otherwise; however, Justice Field noted that no such language existed here. Furthermore, he argued that even if it were possible to assign this type of contract under certain circumstances, those conditions did not exist here as neither party consented to any assignment nor was there evidence of fraud or mistake on either side. As a result, Justice Field concluded by stating his belief that the judgment should have been reversed and remanded back to the lower court with instructions for them to enter judgment in favor of Mr. Holden based on his original agreement with Mr. Joy