Leonard v. Ozark Land Company was a United States Supreme Court case that addressed the issue of whether a party could be held liable for a breach of contract when the contract was not in writing. The case involved a dispute between the plaintiff, Leonard, and the defendant, Ozark Land Company, over a contract for the sale of land. Leonard claimed that he had entered into an oral agreement with Ozark Land Company to purchase a tract of land for a certain price. Ozark Land Company denied that any such agreement had been made and argued that, under the Statute of Frauds, any contract for the sale of land must be in writing. The Supreme Court held that the Statute of Frauds did not apply in this case because the contract was not for the sale of land, but rather for the purchase of land. The Court noted that the Statute of Frauds only applies to contracts for the sale of land, not contracts for the purchase of land. The Court also held that Leonard could recover damages for the breach of contract, even though the contract was not in writing. The Court reasoned that Leonard had provided sufficient evidence to prove that an oral agreement had been made and that Ozark Land Company had breached the agreement.

Justice Field delivered the dissenting opinion in Leonard v. Ozark Land Company, arguing that a state court's decision should not be overturned by the Supreme Court unless it is "clearly erroneous." In this case, he argued that there was no clear error and thus the original ruling of the Arkansas Supreme Court should stand. He noted that while some of his colleagues had found fault with certain aspects of how evidence was weighed or interpreted by lower courts, they did not demonstrate any legal errors on behalf of those courts. Furthermore, Justice Field argued that even if an error had been made in weighing or interpreting evidence, it would have to be so egregious as to constitute reversible error before overturning a state court's decision. As such, he concluded that since no clear legal errors were demonstrated in this case and since none could reasonably be inferred from what occurred below, then there was no basis for reversing the Arkansas Supreme Court’s ruling and thus their judgment should stand.