Roland v. United States was a Supreme Court case that addressed the issue of whether a state court could issue a writ of habeas corpus to a prisoner held in federal custody. The case arose when a prisoner, John Roland, was arrested by federal authorities in the District of Columbia and held in federal custody. Roland sought a writ of habeas corpus from the state court in Maryland, where he was a resident, in order to challenge his detention. 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 power, 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 power to protect its citizens from unlawful detention. The Court concluded that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in federal custody.

In the case of Roland v. United States, the Supreme Court was tasked with determining whether a contract between two parties that had been made in violation of an act passed by Congress could be enforced. The majority opinion held that such contracts were void and unenforceable due to their illegality under federal law. Justice Field dissented from this decision, arguing that while it is true that Congress has the power to pass laws regulating commerce, they do not have the authority to render contracts illegal or invalidate them without providing some form of compensation for those affected by its actions. He argued further that if Congress did possess such powers then it would be able to interfere with private contractual arrangements at will and thus undermine fundamental principles of justice and fairness which are essential for a free society. In conclusion, he stated his belief that any attempt on behalf of Congress to make certain contracts illegal should also include provisions for compensating those who may suffer losses as a result thereof.