Watson v. Sutherland was a case heard by the United States Supreme Court in 1866. The dispute arose when Watson, an African American man, attempted to purchase land from Sutherland but was refused due to his race. Watson then sued for damages and sought relief under the Civil Rights Act of 1866 which granted all citizens equal rights regardless of their race or color. The court held that this act did not apply because it only applied to contracts between individuals and corporations were excluded from its scope; therefore, no damages could be awarded against Sutherland as he had acted on behalf of a corporation at the time of the transaction with Watson. However, Justice Miller wrote in his opinion that Congress had intended for this law to protect African Americans' civil rights and should have been interpreted more broadly than it was by lower courts who denied such claims based on technicalities like those present in this case. Ultimately, while no damages were awarded against Sutherland due to legal technicalities beyond his control, Justice Miller's opinion set forth important principles regarding racial equality before the law which would later become enshrined into federal legislation through subsequent acts passed by Congress over ensuing decades

In Watson v. Sutherland, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a citizen of one state against another in which the cause of action arose from that other state. The majority opinion held that it did not have such jurisdiction and dismissed the case. However, Justice Field dissented on two grounds: firstly, he argued that under Article III Section 2 of the Constitution, Congress has power to confer original jurisdiction upon any State court for cases arising out of another State; secondly, he argued that even if this were not so then there is no reason why a party should be denied access to justice simply because they are citizens of different states. He concluded by stating his belief that "the right ought never to be withheld when its exercise can be fairly and properly invoked".