In Butler v. Watkins, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue a writ of habeas corpus to a federal officer. The case arose when a federal officer, John Butler, was arrested by a state court in Virginia for failing to pay a debt. Butler argued that the state court did not have the authority to issue a writ of habeas corpus because he was a federal officer. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a federal officer. The Court reasoned that the writ of habeas corpus was a federal prerogative and that the state court did not have the authority to interfere with the federal government's power to enforce its laws. 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 it. The Court's decision in Butler v. Watkins established that state courts do not have the authority to issue a writ of habeas corpus to a federal officer. This decision has been cited in numerous cases since then and has been used to protect the rights of federal officers from state interference.

In Butler v. Watkins, the Supreme Court was asked to decide whether a federal court had jurisdiction over an action brought by a former slave against his former master for damages arising from slavery. The majority opinion held that the Thirteenth Amendment did not give Congress power to create such a cause of action and thus denied the plaintiff's claim. Justice Field dissented, arguing that although Congress may not have specifically granted authority to bring this type of suit in federal court, it should be implied as necessary and proper under its powers given by Section 2 of the Thirteenth Amendment. He argued that since slavery was abolished by amendment rather than legislation, any remedy for wrongs committed during slavery must also come through constitutional means rather than statutory law; therefore allowing individuals who were formerly enslaved access to justice in federal courts would be consistent with congressional intent when passing the amendment.