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 federal crime and was serving a sentence of five years. He sought a writ of habeas corpus from the state court of Kansas, claiming that he was being held in violation of the Constitution. The Supreme Court held 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 reasoned that the power to issue a 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 imprison a person convicted of a federal crime. The Court also noted that the state court had no jurisdiction over the federal prison, and thus could not issue a writ of habeas corpus. The Court's decision in Williams v. Bruffy established that state courts do not have the authority to issue a writ of habeas corpus to a prisoner in a federal prison. This decision has been cited in numerous subsequent cases, and has been used to support the principle that the federal government has exclusive authority over federal prisoners.

Justice Field delivered the dissenting opinion in Williams v. Bruffy, arguing that the majority had misinterpreted a prior decision of the Supreme Court and failed to consider its implications for this case. He argued that under the law as it stood at the time, an individual who was not a party to a contract could still be held liable if they were found to have participated in or aided with carrying out its terms. In this case, he believed that there was sufficient evidence presented by Williams showing that Bruffy had been involved in aiding his father-in-law's breach of contract and should therefore be held responsible for damages incurred by Williams as a result. Justice Field concluded by stating his belief that "the court has gone too far" in limiting liability only to those who are parties to contracts when other individuals may also be involved with their performance or enforcement.