In Brooks v. Clark, the United States Supreme Court 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 federal custody. The case arose when a prisoner, Brooks, was arrested and held in federal custody in the District of Columbia. Brooks sought a writ of habeas corpus from the state court of the District of Columbia, claiming that he was being held in violation of the Constitution. The federal government argued that the state court did not have the authority to issue a writ of habeas corpus in a federal case. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus in a federal case. The Court reasoned that the power to issue a writ of habeas corpus was a power reserved to the federal government, and that the state court did not have the authority to interfere with the federal government's power. The Court also noted that the state court had no jurisdiction over the federal government, and thus could not issue a writ of habeas corpus. In conclusion, the Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus in a federal case. The Court reasoned that the power to issue a writ of habeas corpus was a power reserved to the federal government, and that the state court did not have the authority to interfere with the federal government's power. The Court also noted that the state court had no jurisdiction over the federal government, and thus could not issue a writ of habeas corpus.

Justice Field delivered the dissenting opinion in Brooks v. Clark, arguing that a state court had no authority to issue an injunction against a federal officer who was acting within his lawful powers. He argued that such action would be contrary to the Supremacy Clause of the Constitution and could not be allowed by any court. Furthermore, he noted that even if it were possible for a state court to enjoin such an act, this particular case did not present sufficient evidence of wrongdoing on behalf of the defendant or harm caused by him as required under established law for granting injunctive relief. Justice Field concluded his dissent with strong words about how allowing states courts to interfere with federal officers' duties would undermine our system of government and lead us down "a path which leads directly into anarchy."