In Keith v. Clark, the United States Supreme Court was asked to decide whether a state court had the authority to issue a writ of habeas corpus to a prisoner held in federal custody. The petitioner, William Keith, was a prisoner in the custody of the United States Marshal for the District of Columbia. He had been convicted of a crime in the District of Columbia and was serving a sentence in the federal penitentiary. The petitioner sought a writ of habeas corpus from the Supreme Court of the District of Columbia, claiming that he had been denied due process of law in his trial. The Supreme Court of the District of Columbia granted the writ and ordered the United States Marshal to produce the prisoner before the court. The United States Marshal refused to comply with the order, and the Supreme Court of the District of Columbia then issued a writ of attachment against the Marshal. The Supreme Court of the United States held that the Supreme Court of the District of Columbia did not have the authority to issue the writ of habeas corpus or the writ of attachment. The Court reasoned that the power to issue writs of habeas corpus was vested exclusively in the federal courts, and that the state courts had no authority to interfere with the federal government's power to detain prisoners. The Court also held that the writ of attachment was invalid because it was issued without the authority of the United States Congress.

Justice Field delivered the dissenting opinion in Keith v. Clark, arguing that the majority had erred in its decision to uphold a lower court ruling which found that an individual who was born into slavery and later emancipated by his master could not bring suit against another party for damages resulting from being held as a slave. Justice Field argued that this decision violated both natural law and public policy, noting that it would be unjust to deny someone their right to seek redress for wrongs committed against them simply because they were once enslaved. He further noted that such a ruling would create an incentive for individuals to keep slaves even after emancipation since they would no longer have any legal recourse if those same former slaves were mistreated or abused afterwards. In conclusion, Justice Field argued strongly against the majority's position on this case and urged them to reconsider their stance so as not to condone injustice or encourage future enslavement of African Americans.