Kidd v. Johnson 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 who was being held in a federal prison. The case arose when a prisoner, William Kidd, was held in a federal prison in the state of Virginia. Kidd had been convicted of a crime in the state of Virginia and was serving his sentence in the federal prison. Kidd then filed a petition for a writ of habeas corpus in the state court, arguing that he was being unlawfully detained in the federal prison. 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 remedy and that the state court did not have the authority to issue such a writ. The Court also noted that the state court did not have the authority to review the legality of a federal conviction. The Court concluded that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison.

Justice Field delivered the dissenting opinion in Kidd v. Johnson, arguing that the majority's decision was wrongfully based on an erroneous interpretation of a state statute. He argued that the court should have interpreted the statute more broadly and applied it to all cases where there is a contract for personal services, regardless of whether or not those services are rendered by an agent or employee. In his view, this would be consistent with both common law principles and public policy considerations which dictate that contracts should be enforced according to their terms whenever possible. Furthermore, he noted that if such contracts were not enforceable then employers could easily take advantage of employees who had no other means of recourse against them due to lack of legal knowledge or resources. Justice Field concluded by urging caution when interpreting statutes so as not to limit rights unnecessarily without clear legislative intent otherwise stated in plain language within the text itself.