Lincoln v. French 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 held in federal custody. The case arose when the petitioner, William Lincoln, was arrested by federal officers in the District of Columbia and taken to the state of Maryland, where he was held in federal custody. The state of Maryland then issued a writ of habeas corpus to the federal officers, ordering them to produce Lincoln before the state court. The federal officers refused to comply with the writ, and the state court then issued a writ of attachment against the federal officers, ordering them to appear before the court and show cause why they should not be held in contempt. The Supreme Court held that the state court did not have the authority to issue the writ of habeas corpus or the writ of attachment. The Court reasoned that the writ of habeas corpus was a federal prerogative, and that the state court did not have the authority to interfere with the federal government's exercise of its power. The Court also held that the writ of attachment was an improper exercise of the state court's power, as it was an attempt to coerce the federal officers into complying with the writ of habeas corpus. The Court concluded that the state court had exceeded its authority in issuing the writs, and that the federal officers were not required to comply with them.

Justice Field delivered the dissenting opinion in Lincoln v. French, arguing that the majority had failed to consider a key issue of law: whether or not an action for damages could be brought against a state officer who was acting within his authority and under color of office. He argued that such an action should only be allowed if it can be shown that the officer acted maliciously or without probable cause. In this case, he believed there was no evidence to suggest either malice or lack of probable cause on behalf of defendant French, so any judgment against him would violate his constitutional rights as well as those granted by Congress through its legislation granting immunity from suit to certain officers performing their official duties. Justice Field concluded by noting that while states may have some power over their own officers, they cannot grant them absolute immunity from civil actions; rather, each case must be judged on its merits and with due consideration given to all relevant facts before determining whether liability is appropriate in any particular instance.