In Litchfield v. Goodnow's Administrator, the Supreme Court of the United States was asked to decide whether a state court had the authority to grant a new trial in a case that had already been decided by a federal court. The case involved a dispute between the administrator of the estate of a deceased man, and the heirs of the deceased man. The administrator had brought a suit in a state court to recover certain property that had been left to the deceased man by his father. The heirs of the deceased man argued that the property had been left to them by the deceased man's father, and that the administrator had no right to it. The state court granted the administrator's motion for a new trial, and the heirs appealed to the Supreme Court. The Supreme Court held that the state court did not have the authority to grant a new trial in a case that had already been decided by a federal court. The Court reasoned that the state court was bound by the decision of the federal court, and that it could not grant a new trial in a case that had already been decided by a federal court. The Court also held that the state court had no authority to grant a new trial in a case that had already been decided by a federal court.

In Litchfield v. Goodnow's Administrator, the Supreme Court was tasked with deciding whether a contract between two parties could be enforced when it had been made without consideration and in violation of a state statute. The majority opinion held that the contract was not enforceable because it lacked consideration and violated public policy as expressed by the state statute. Justice Field dissented from this decision, arguing that while contracts lacking consideration are generally unenforceable, there were exceptions to this rule which should apply in this case. He argued that if one party had already performed their obligations under the agreement then they should still be able to recover damages for breach of contract even though no new considerations existed at the time of enforcement. Furthermore, he argued that since both parties intended to enter into an agreement and did so voluntarily without any fraud or duress being involved then enforcing such an agreement would not violate public policy as expressed by the state statute but rather promote justice between them both.