Pullman v. Upton 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 held in federal custody. The case arose when the petitioner, Pullman, was arrested by federal officers and held in federal custody. Pullman then sought a writ of habeas corpus from the state court, which the state court granted. The federal government then 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 federal custody. The Court reasoned that the writ of habeas corpus was a federal prerogative and that the state court did not have the authority to interfere with the federal government's power to detain a prisoner. The Court also noted that the writ of habeas corpus was a fundamental right and that the federal government had the exclusive power to issue such writs. 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 held in federal custody. The Court reasoned that the writ of habeas corpus was a federal prerogative and that the state court did not have the authority to interfere with the federal government's power to detain a prisoner.

Justice Field delivered the dissenting opinion in Pullman v. Upton, arguing that the majority's decision was inconsistent with prior Supreme Court precedent and would lead to confusion among lower courts. He argued that the court should not have considered evidence outside of what was presented at trial because it could be used to create a new set of facts which were not part of the original case. Furthermore, he believed that allowing such evidence would open up a Pandora's box for future cases as litigants could use this ruling to introduce any kind of extrinsic evidence into their cases regardless if it had been previously excluded by lower courts or even if it contradicted established law. Justice Field concluded his dissent by stating that while he agreed with some parts of the majority opinion, he felt strongly enough about this issue to make sure his views were heard on record so as not to leave any doubt about where he stood on this matter.