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Callan v. Wilson

• 1887 • 127 U.S. 540 • Waite Court
Callan v. Wilson was a United States Supreme Court case that addressed the issue of whether a state court could issue a writ of habeas corpus to a prisoner held in federal custody. The case arose when a prisoner, Callan, was held in federal custody in the state of California. Callan sought a writ of habeas corpus from the state court, which was denied by the state court on the grounds that it lacked jurisdiction over federal prisoners. Callan then appealed to the Supreme Court. The Supreme...Open Case
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Chief Waite Court
Term: 1887
Docket: 1318
127 U.S. 540
8 S. Ct. 1301
32 L. Ed. 223
1888 U.S. LEXIS 2017
Argued: Jan 16, 1888

Callan v. Wilson

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Opinion Summary
AI Abstract

Callan v. Wilson was a United States Supreme Court case that addressed the issue of whether a state court could issue a writ of habeas corpus to a prisoner held in federal custody. The case arose when a prisoner, Callan, was held in federal custody in the state of California. Callan sought a writ of habeas corpus from the state court, which was denied by the state court on the grounds that it lacked jurisdiction over federal prisoners. Callan then appealed to the Supreme Court. The Supreme Court held that the state court did not have jurisdiction to issue a writ of habeas corpus to a prisoner held in federal custody. The Court reasoned that the writ of habeas corpus was a federal remedy and that the state court lacked the power to issue such a writ. The Court further held that the state court could not interfere with the federal government's power to detain a prisoner in federal custody. In conclusion, the Supreme Court held that the state court lacked jurisdiction to issue a writ of habeas corpus to a prisoner held in federal custody. The Court reasoned that the writ of habeas corpus was a federal remedy and that the state court lacked the power to issue such a writ. The Court further held that the state court could not interfere with the federal government's power to detain a prisoner in federal custody.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Callan v. Wilson, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that although a state may have laws which restrict certain rights of citizens, those restrictions must not violate any constitutional provisions or other federal law. In this case, he believed that the statute at issue did indeed violate both Article IV of the Constitution as well as Section 1983 of Title 42 of United States Code (USC). Justice Field noted that under Article IV, states are required to give full faith and credit to public acts from other states; however, by enacting a statute which prohibited non-residents from recovering damages for injuries sustained while in their state violated this provision. Additionally, Section 1983 provided all persons with protection against deprivation of life or liberty without due process - something which had been denied to Mr. Callan through his inability to recover damages for his injury due to being a non-resident when it occurred. Therefore Justice Field concluded that since these two statutes were violated by Wisconsin's enactment prohibiting recovery for non-residents injured within its borders then it should be declared unconstitutional and overturned on appeal

Opinion written by Justice JHarlan(1)
Decided: May 14, 1888
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