Wiggins et al. v. Burkham was a case heard by the United States Supreme Court in 1869. The case involved a dispute between two parties over the ownership of a piece of land in the state of Mississippi. The plaintiffs, Wiggins et al., claimed that they had purchased the land from the defendant, Burkham, and that Burkham had failed to deliver the deed to them. The defendant argued that he had never sold the land to the plaintiffs and that they had no legal right to it. The Supreme Court ultimately ruled in favor of the plaintiffs, finding that Burkham had indeed sold the land to them and that he had failed to deliver the deed. The Court held that the plaintiffs had a valid claim to the land and that Burkham was liable for damages for his failure to deliver the deed. The Court also held that the plaintiffs were entitled to recover the purchase price of the land, as well as any other damages they had suffered as a result of Burkham's breach of contract. This ruling established the principle that a party who fails to deliver a deed to a purchaser of land is liable for damages.

In the case of Wiggins et al. v. Burkham, Justice Field dissented from the majority opinion that a state court had jurisdiction to hear a suit brought by an African American against another African American for damages resulting from trespass on land owned by the plaintiff in California. He argued that under Article IV Section 2 of the United States Constitution, which states “The Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States”, this suit should have been heard in federal court as it was based upon rights granted only to citizens and not those held by non-citizens or aliens such as Chinese immigrants who were also living in California at this time. Furthermore, he noted that since there was no diversity between parties involved (both being African Americans) then federal courts would still have jurisdiction over such cases even if they did not involve any privileges or immunities granted exclusively to citizens. Therefore he concluded that due process had been denied when this case was decided solely within state courts without consideration for whether it fell within federal jurisdiction first