Lee v. Dodge was a case heard by the United States Supreme Court in 1864. The plaintiff, Lee, had been hired to work on a farm owned by Dodge and his wife for one year at an agreed upon wage of $400. After working for only four months, Lee left the job due to ill health but did not receive any wages from Dodge or his wife despite having fulfilled all of their obligations under the contract. The court found that although there was no express agreement between Lee and Dodge regarding payment if he left before completing the full term of employment, it would be unjust enrichment for them to keep all of his wages without paying him anything in return since they had received benefit from his labor during those four months. Therefore, they were ordered to pay him $200 as compensation for services rendered up until that point in time.

In Lee v. Dodge, the Supreme Court was asked to decide whether a state court had jurisdiction over a case involving an alleged breach of contract between two citizens of different states. The majority opinion held that the state court did have jurisdiction and could hear the case. However, Justice Field dissented from this decision on several grounds. He argued that since both parties were citizens of different states, it should be up to Congress to determine which court has jurisdiction in such cases as they are matters affecting interstate commerce and thus fall under federal authority rather than being left solely for individual states to decide upon. Furthermore, he noted that if each state is allowed its own interpretation regarding these types of disputes then there would be no uniformity or consistency in how such cases are handled across all jurisdictions which could lead to confusion and uncertainty among litigants who may not know where their rights lie depending on what particular forum they choose for resolution of their dispute.