In the 1906 case of Bachtel v. Wilson, Sheriff, the U.S. Supreme Court dealt with a dispute over an arrest warrant issued in Ohio for Charles Bachtel who was residing in West Virginia at that time. The Governor of Ohio requested his extradition from West Virginia to face charges related to embezzlement and larceny while he served as treasurer of Stark County, Ohio. However, Bachtel argued that these were not extraditable offenses under existing laws between states and sought protection from being returned to Ohio by filing a habeas corpus petition. The court ruled against him stating that both crimes were indeed covered under interstate extradition laws which allowed for individuals charged with "treason, felony or other crime" to be delivered up on demand of the executive authority where they are accused but found in another state. This ruling upheld the principle that governors have broad discretion when determining whether or not someone should be extradited back to their home state.

In the dissenting opinion for Bachtel v. Wilson, Sheriff (1906), Justice Harlan disagreed with the majority's decision to deny habeas corpus relief to a prisoner who was convicted by a jury that included members who had preconceived notions about his guilt. He argued that this violated the defendant's constitutional right to an impartial trial and due process of law. The justice believed that if any juror enters into a trial with prejudice or bias against the accused, it undermines their ability to make fair judgments based on evidence presented in court. Therefore, he contended that such trials are fundamentally unfair and violate basic principles of justice enshrined in U.S constitution.