In Church v. Kelsey, 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 prisoner who was being held in federal custody. The petitioner, Church, was a prisoner in the custody of the United States Marshal, and he sought a writ of habeas corpus from the state court. The United States argued that the state court did not have the authority to issue the writ, as the federal government had exclusive jurisdiction over the prisoner. The Supreme Court held that the state court did not have the authority to issue the writ of habeas corpus. The Court reasoned that the federal government had exclusive jurisdiction over the prisoner, and that the state court did not have the authority to interfere with the federal government's authority. The Court also noted that the writ of habeas corpus was a remedy for state prisoners, and that the federal government had its own remedies for federal prisoners. The Court's decision in Church v. Kelsey established that the federal government has exclusive jurisdiction over federal prisoners, and that state courts do not have the authority to issue writs of habeas corpus to federal prisoners. This decision has been cited in numerous cases since then, and it remains an important precedent in the area of federal-state relations.

Justice Field delivered the dissenting opinion in Church v. Kelsey, arguing that a state court had no authority to interfere with the internal affairs of a religious society. He argued that it was not within the power of any government to control or regulate matters which are purely spiritual and ecclesiastical, as they were beyond its jurisdiction and competence. Furthermore, he noted that if such interference were allowed then there would be no end to litigation between members of different denominations on questions relating solely to their faith and practice. Justice Field concluded by stating that while states have an interest in protecting citizens from frauds perpetrated under cover of religion, this case did not involve any fraudulent practices but rather concerned only matters pertaining exclusively to religious doctrine and discipline - something which should remain outside the purview of civil courts.