Burnham and Another v. Bowen 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 who was being held in a federal prison. The case arose when two prisoners, Burnham and another, were held in a federal prison in the state of California. The prisoners sought a writ of habeas corpus from the state court, claiming that they were being held in violation of their constitutional rights. The state court granted the writ, and the federal government appealed the decision to the Supreme Court. 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 remedy, and that the state court did not have the power to interfere with the federal government's authority to imprison individuals. The Court also noted that the writ of habeas corpus was a remedy that could only be used to challenge the legality of a person's detention, and not to challenge the conditions of the detention. The Court concluded that the state court had no authority to issue a writ of habeas corpus to a prisoner held in a federal prison.

Justice Harlan wrote a dissenting opinion in the case of Burnham and Another v. Bowen, arguing that the court should have found for the plaintiff on their claim under Section 2 of the Fourteenth Amendment. He argued that since state law had allowed Mrs. Burnham to inherit her husband's property upon his death, she was entitled to protection from any subsequent changes made by Congress or other states which would take away this right without due process of law. Furthermore, he argued that if Congress could pass laws taking away rights granted by state laws without providing due process then it would be an unconstitutional infringement on states' rights and powers reserved for them under the Tenth Amendment. Justice Harlan concluded his dissent with a warning against allowing such power grabs as they could lead to further erosion of individual liberties protected by both federal and state constitutions alike.