Clark v. Keith 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 a prisoner, William Clark, was held in a federal prison in Illinois. Clark sought a writ of habeas corpus from the state court, claiming that he was being held in violation of the Constitution. 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 merits of the underlying conviction. The Court's decision in Clark v. Keith established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons. The decision also clarified the scope of the writ of habeas corpus, and established that it could only be used to challenge the legality of a person's detention, and not to challenge the merits of the underlying conviction.

Justice Field delivered the dissenting opinion in Clark v. Keith, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that under California law, a married woman had no right to convey property without her husband's consent or signature; thus, Mrs. Clark could not have conveyed title of the land at issue in this case by herself alone. Furthermore, Justice Field noted that even if she did possess such a power under state law (which he believed she did not), it would still be subject to her husband’s control as head of their household and his right to manage all family affairs - including real estate transactions - unless otherwise provided for by statute or contract between them. Therefore, since Mr. Clark never consented nor signed any documents related to his wife’s purported sale of the land at issue here, Justice Field concluded that there was no valid transfer of title from Mrs. Clark to respondent Keith and therefore held that judgment should have been entered for Mr