Kurtz v. Moffitt & Another 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, John Kurtz, was held in a federal prison in California. Kurtz sought a writ of habeas corpus from the California Supreme Court, claiming that he was being held in violation of the Constitution. The California Supreme Court granted the writ, and the federal government appealed to the United States Supreme Court. The Supreme Court held that the California Supreme 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 held that the writ of habeas corpus was a remedy that could only be used to challenge the legality of a prisoner's detention, and not to challenge the conditions of the prisoner's confinement. The Court concluded that the California Supreme Court had exceeded its authority in issuing the writ of habeas corpus to Kurtz.

Justice Field delivered the dissenting opinion in Kurtz v. Moffitt & Another, arguing that Congress had no authority to pass a law which would allow for the recovery of damages from an individual who was not party to a contract. He argued that such a law would be unconstitutional and violate due process rights as it allowed individuals to sue without any notice or opportunity for defense. Furthermore, he argued that this type of legislation could lead to abuse by allowing people with malicious intent to bring suits against innocent parties without proper cause. Justice Field concluded his dissent by stating that if Congress wanted citizens' property rights protected they should do so through constitutional means rather than passing laws which violated due process and were ultimately unenforceable in court.