In the case of Bowen v. Johnston, the U.S. Supreme Court ruled in 1938 that a federal court has jurisdiction to issue habeas corpus relief for prisoners who are held in custody by state authorities but were convicted under federal law. The petitioner, Bowen, was charged with violating the Dyer Act (a federal law prohibiting transportation of stolen vehicles across state lines) and sentenced by a United States District Court sitting within California but outside its district boundaries due to an emergency proclamation issued by President Roosevelt during a San Francisco labor strike. After being transferred to Alcatraz prison, he filed for writs of habeas corpus arguing his conviction was invalid because it occurred outside proper territorial jurisdiction. The lower courts denied his petitions on grounds they lacked authority over him since he was now held in custody under State authority at Alcatraz Island which belonged to California not Federal Government as per an 1850 act admitting California into Union. However, the Supreme Court reversed these decisions stating that despite physical location or custodian's identity (state or federal), if prisoner is detained due to violation of US laws then Federal Courts have power and responsibility towards such cases including issuing writs like Habeas Corpus.

In the dissenting opinion for Bowen v. Johnston, Justice McReynolds disagreed with the majority's decision to grant a writ of habeas corpus to Johnston. He argued that federal courts should not interfere in state court proceedings unless there is clear evidence of an egregious violation of constitutional rights. In this case, he believed that such evidence was lacking and therefore, it was inappropriate for the Supreme Court to intervene in what he viewed as a matter best left to state jurisdiction. Furthermore, Justice McReynolds expressed concern about setting a precedent where federal courts could easily overrule decisions made by state courts based on their own interpretations of law and constitutionality.