Muller v. Dows was a United States Supreme Court case that addressed the issue of whether a state court could issue a writ of error to a federal court. The case involved a dispute between two parties, Muller and Dows, over a contract for the sale of land. Muller had sued Dows in a federal court, and Dows had appealed the decision to the state court. The state court then issued a writ of error to the federal court, which Muller argued was an unconstitutional exercise of power. The Supreme Court held that the state court did not have the authority to issue a writ of error to the federal court. The Court reasoned that the state court was not a court of appeals for the federal court, and that the state court did not have the power to review the decisions of the federal court. The Court also noted that the state court had no jurisdiction over the case, as it was a dispute between two parties in a federal court. The Court concluded that the state court had exceeded its authority by issuing a writ of error to the federal court, and that the writ of error was therefore invalid. The Court also held that the state court had no power to review the decisions of the federal court. This decision established the principle that state courts cannot issue writs of error to federal courts.

Justice Field delivered the dissenting opinion in Muller v. Dows, arguing that the majority's decision was incorrect and should be reversed. He argued that under California law, a mortgagee had no right to foreclose on a mortgagor without first obtaining an order from the court authorizing it to do so. The majority held that such an order was not necessary because of certain language in the mortgage agreement between Muller and Dows; however, Justice Field disagreed with this interpretation of California law. He noted that even if there were some ambiguity as to whether or not such an order was required by state law, it would still be prudent for a mortgagee to obtain one before attempting foreclosure proceedings against its mortgagor. Furthermore, he argued that since both parties agreed at trial that such an order must be obtained prior to any foreclosure action being taken against them, then they should have been bound by their own stipulation regardless of what other laws may say about it. In conclusion, Justice Field believed strongly enough in his dissent position on this case so as to call for reversal of the majority's ruling which allowed Dows' foreclosure attempt without first obtaining court authorization for doing so