In Williams v. Bruffy, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue a writ of habeas corpus to a prisoner who was being held in a federal prison. The petitioner, Williams, was a prisoner in the federal penitentiary in Leavenworth, Kansas. He had been convicted of a crime in the state of Missouri and was serving his sentence in the federal prison. He sought a writ of habeas corpus from the state court in Missouri, claiming that his conviction was unconstitutional. The state court granted the writ and ordered the federal prison to release Williams. The federal government appealed the decision to the Supreme Court, arguing that the state court did not have the authority to issue a writ of habeas corpus to a prisoner in a federal prison. The Supreme Court agreed with the federal government, ruling that the state court did not have the authority to issue a writ of habeas corpus to a prisoner in a federal prison. The Court held that the power to issue a writ of habeas corpus was vested exclusively in the federal government, and that the state court had no authority to interfere with the federal prison system.

Justice Field delivered the dissenting opinion in Williams v. Bruffy, arguing that the majority had misconstrued the law and failed to consider all of its implications. He argued that a contract for personal services could not be assigned without consent from both parties, as it would violate public policy by allowing one party to escape their obligations while forcing another into an agreement they did not make or agree to. Furthermore, he noted that if such contracts were assignable then employers would have no incentive to pay employees on time since they could simply transfer their debt onto someone else with relative ease. As such, Justice Field concluded that any assignment of this nature should be considered void and unenforceable under existing laws and regulations.