Kibbe v. Benson was a United States Supreme Court case that addressed the issue of whether a state court had the authority to grant a divorce to a married couple. The case involved a married couple, Mr. and Mrs. Benson, who had been living apart for several years. Mrs. Benson had filed for a divorce in the state court of New York, and the court had granted the divorce. Mr. Benson then appealed the decision to the Supreme Court, arguing that the state court did not have the authority to grant a divorce. The Supreme Court ultimately ruled in favor of Mrs. Benson, holding that the state court did have the authority to grant a divorce. The Court reasoned that the state court had the power to grant a divorce because the state had the power to regulate marriage and divorce within its borders. The Court also noted that the state court had acted within its authority in granting the divorce, as the couple had been living apart for several years and there was no evidence of any misconduct on either party's part. In conclusion, the Supreme Court held that the state court had the authority to grant a divorce to the married couple in Kibbe v. Benson. The Court reasoned that the state had the power to regulate marriage and divorce within its borders, and that the state court had acted within its authority in granting the divorce.

Justice Field delivered the dissenting opinion in Kibbe v. Benson, arguing that the majority's decision was a misinterpretation of the law and would lead to an unjust result. He argued that under existing laws, when a contract is made between two parties for goods or services, it must be performed according to its terms unless there is some legal excuse for not doing so. In this case, he argued that no such excuse existed because Benson had agreed to pay Kibbe $2 per acre for his land but then refused to do so after receiving title from him. Therefore, Justice Field concluded that Kibbe should have been allowed to recover damages from Benson as provided by law and urged reversal of the judgment below on those grounds.