Townsend v. Burbank was a case heard by the United States Supreme Court in 1866. The dispute arose when Townsend, an African-American man, sued Burbank for breach of contract after he had been hired to work on his farm and then discharged without pay or compensation. Townsend argued that under the Thirteenth Amendment of the U.S Constitution, which abolished slavery and involuntary servitude, he should be compensated for his labor as if it were free labor instead of being treated like a slave who could not receive any wages or benefits from their employer. The Supreme Court agreed with Townsend's argument and held that since slavery had been abolished by the Thirteenth Amendment, all persons must be paid fair wages regardless of race or color; thus making this ruling one of the first cases to recognize equal protection rights for African Americans under federal law.

In Townsend v. Burbank, the Supreme Court was asked to determine whether a state court had jurisdiction over an action brought by a citizen of one state against another in which the plaintiff sought damages for breach of contract. The majority opinion held that such actions were not within the scope of federal judicial power and thus could not be heard in a federal court. Justice Field dissented from this decision, arguing that under Article III of the Constitution, Congress has exclusive authority to regulate cases arising between citizens of different states and therefore it should have been allowed to hear this case. He further argued that since there was no dispute as to what law applied or any other issue requiring interpretation by a higher court, it would have been appropriate for Congress to exercise its discretion and allow this case before them instead of leaving it solely up to individual states' courts. In conclusion, Justice Field believed that allowing only state courts jurisdiction over these types of disputes deprived individuals from having their rights adjudicated on equal terms with those residing in other states; something he felt was contrary both "to justice" and "the spirit" behind our nation's founding documents.