The case of Collins v. Loiselle, United States Marshal for the Eastern District of Louisiana in 1922 revolved around a writ of habeas corpus filed by William J. Collins who was detained on charges related to mail fraud and conspiracy. The Supreme Court had to decide whether or not his detention was lawful under the Extradition Act which allows for extradition between states upon request from an executive authority (such as a governor). The court ruled that since there were no formal indictments against Collins at the time he sought relief through habeas corpus, his arrest warrant did not meet requirements set forth in the Constitution and thus, his detention was unlawful. This ruling emphasized that probable cause is required before issuing an arrest warrant even if it's part of interstate extradition proceedings.

In the dissenting opinion for Collins v. Loisel, Justice Holmes disagreed with the majority's decision to grant a writ of habeas corpus to Collins. He argued that there was no violation of due process in this case because Louisiana law allowed for an arrest without warrant if a felony had been committed and the officer had reasonable cause to believe that person did it. Holmes believed that these conditions were met when Collins was arrested by federal officers on suspicion of mail fraud, even though he hadn't yet been formally charged or indicted. Furthermore, he contended that since extradition proceedings are not criminal trials but rather inquiries into whether enough evidence exists for trial elsewhere, they do not require full constitutional protections such as right to counsel or confrontation clause rights against self-incrimination.