Martin v. Cole 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 who was being held in a federal prison. The case arose when a prisoner, Martin, was held in a federal prison in the state of Georgia. Martin sought a writ of habeas corpus from the state court, claiming that he was being held in violation of the Constitution. The state court granted the writ, and the federal government appealed the decision to the Supreme Court. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The Court reasoned that the writ of habeas corpus was a federal remedy, and that the state court did not have the power to interfere with the federal government's authority to imprison individuals. The Court also noted that the writ of habeas corpus was a remedy that could only be used to challenge the legality of a person's detention, and not to challenge the conditions of the detention. The Court's decision in Martin v. Cole established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons. This decision has been cited in numerous subsequent cases, and has been used to support the principle that state courts cannot interfere with the federal government's authority to imprison individuals.

Justice Field delivered the dissenting opinion in Martin v. Cole, arguing that the majority decision was wrongfully decided and should be reversed. He argued that a contract between two parties is binding on both of them, regardless of any subsequent changes to state laws or regulations regarding such contracts. In this case, he noted that when the contract was made between Martin and Cole it did not violate any existing law or regulation; however, after their agreement had been reached a new law was passed which prohibited such agreements from being enforced by courts. Justice Field believed this new law could not be applied retroactively to invalidate an already-existing contract as doing so would amount to an unconstitutional taking without due process of law. Furthermore, he maintained that if one party were allowed to break their contractual obligations simply because they no longer wished to fulfill them then all contracts would become unenforceable and society would suffer greatly as a result.