Woodruff v. Parham was a United States Supreme Court case that dealt with the issue of whether a state court had the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The case arose when a prisoner, Woodruff, was held in a federal prison in Georgia and sought a writ of habeas corpus from the state court. The state court granted the writ, but the federal government argued that the state court did not have the authority to issue the writ. The Supreme Court ultimately held that the state court did not have the authority to issue the writ of habeas corpus. The Court reasoned that the 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 individuals. The Court also noted that the writ of habeas corpus was a fundamental right, and that the state court should not be allowed to interfere with the federal government's power to protect this right. In conclusion, the Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. The Court reasoned that the writ of habeas corpus was a federal power, and that the state court should not be allowed to interfere with the federal government's power to protect this right.

In Woodruff v. Parham, the Supreme Court was asked to decide whether a contract between two parties that had been partially performed could be enforced by one of the parties against the other. The majority opinion held that it could not, as there were no mutual promises made and therefore no consideration for either party's promise. However, in his dissenting opinion Justice Field argued that even though there was only one promise made by one of the parties, this should still be considered valid because it had already been partially performed and thus constituted sufficient consideration for its enforcement. He further argued that if partial performance is not taken into account when deciding on enforceability then contracts would become unenforceable due to minor technicalities which would lead to injustice and confusion in commercial transactions.