Holland v. Challen was a United States Supreme Court case that addressed the issue of whether a state court had the authority to issue a writ of habeas corpus to a federal court. The case involved a dispute between two parties, Holland and Challen, over a contract for the sale of a steamboat. Holland had obtained a judgment against Challen in a state court, and Challen sought to have the judgment set aside by filing a petition for a writ of habeas corpus in a federal court. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a federal court, and that the federal court had exclusive jurisdiction over the matter. The Court also held that the state court's judgment was not binding on the federal court. The decision established the principle that state courts do not have the authority to issue writs of habeas corpus to federal courts.

Justice Field delivered the dissenting opinion in Holland v. Challen, arguing that the majority's decision was incorrect and should be reversed. He argued that Congress had not intended to create a new species of property when it passed the Homestead Act of 1862; rather, he believed that Congress had merely sought to provide an opportunity for citizens who were unable to purchase land outright with cash or credit. Furthermore, Justice Field argued that even if such a species of property did exist under the act, it would still be subject to state laws governing real estate transactions and could not be exempted from them by federal law. Finally, he noted that while there may have been some ambiguity in how certain provisions of the act were interpreted by different courts at different times over its history, this did not mean those interpretations should remain unchanged forever without congressional action or further judicial review. In conclusion, Justice Field concluded his dissent by stating his belief that "the construction adopted [by]...the court below is correct."