Miltberger v. Cooke was a United States Supreme Court case that addressed the issue of whether a state court had the authority to issue a writ of habeas corpus to a prisoner who had been convicted in a federal court. The case arose when a prisoner, Miltberger, was convicted in a federal court and sentenced to imprisonment. Miltberger then sought a writ of habeas corpus from a state court, claiming that his conviction was unconstitutional. The state court granted the writ and ordered Miltberger released from prison. The Supreme Court held that the state court did not have the authority to issue the writ of habeas corpus. 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 a federal conviction. The Court further held that the state court's action was an unconstitutional interference with the federal court's jurisdiction. In conclusion, the Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner who had been convicted in a federal court. 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 a federal conviction. The Court further held that the state court's action was an unconstitutional interference with the federal court's jurisdiction.

Justice Field delivered the dissenting opinion in Miltberger v. Cooke, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that under Missouri law, a contract of sale is not binding until it has been accepted by both parties to the agreement. In this case, he noted that there had been no acceptance of the offer made by Cooke to purchase Miltberger’s land; therefore, there could be no valid contract between them. Furthermore, Justice Field asserted that even if an oral agreement had been reached between Cooke and Miltberger for him to purchase her land at a certain price with payment due within two years from date of delivery of deed - as alleged by plaintiff - such an arrangement would still have required some form of written evidence or memorandum in order for it to be legally enforceable under Missouri law. As none existed here, he concluded that any claim based on such an alleged verbal agreement must fail as a matter of law and thus affirmed his dissent from the majority opinion which held otherwise.