Lucas v. Brooks was a United States Supreme Court case that addressed the issue of whether a state court could grant a divorce on the grounds of adultery when the parties had already been divorced in another state. The Supreme Court held that a state court could not grant a divorce on the grounds of adultery when the parties had already been divorced in another state. The case arose when the plaintiff, Lucas, filed for divorce in the state of Mississippi on the grounds of adultery. The defendant, Brooks, had already been divorced from Lucas in the state of Arkansas. The Mississippi court granted the divorce on the grounds of adultery, and Brooks appealed the decision to the Supreme Court. The Supreme Court held that a state court could not grant a divorce on the grounds of adultery when the parties had already been divorced in another state. The Court reasoned that the state of Arkansas had already granted the divorce, and that the Mississippi court could not grant a second divorce on the same grounds. The Court also noted that the Mississippi court had no jurisdiction over the parties, as they were not residents of Mississippi. In conclusion, the Supreme Court held that a state court could not grant a divorce on the grounds of adultery when the parties had already been divorced in another state. The Court reasoned that the state of Arkansas had already granted the divorce, and that the Mississippi court had no jurisdiction over the parties.

Justice Field delivered the dissenting opinion in Lucas v. Brooks, arguing that the majority's decision was contrary to both precedent and sound legal reasoning. He argued that a contract for personal services is not assignable without the consent of all parties involved, and thus it could not be assigned by one party to another without such consent. Furthermore, he noted that if an assignment were allowed in this case then any other contracts involving personal services would also be subject to assignment regardless of whether or not they had been made with specific individuals in mind. Finally, Justice Field asserted that allowing assignments like these would create uncertainty as to who was actually responsible for performing certain tasks under a contract since there may have been multiple assignments over time which could lead to confusion about who should fulfill their obligations under said contract.