Dold v. United States was a Supreme Court case that addressed the issue of whether a federal court had the authority to issue a writ of habeas corpus to a prisoner who was being held in a state prison. The case arose when a prisoner, John Dold, was convicted of a crime in a state court and sentenced to a term of imprisonment. Dold then filed a petition for a writ of habeas corpus in a federal court, arguing that his conviction was unconstitutional. The federal court granted the writ and ordered the state to release Dold. The state of Illinois appealed the decision to the Supreme Court, arguing that the federal court did not have the authority to issue the writ. The Supreme Court agreed with the state, ruling that the federal court did not have the authority to issue the writ. The Court reasoned that the writ of habeas corpus was a state prerogative and that the federal court could not interfere with the state's authority. The Court also noted that the writ of habeas corpus was a remedy for violations of federal law, and that Dold had not alleged any such violations. The decision in Dold v. United States established that federal courts do not have the authority to issue writs of habeas corpus to prisoners held in state prisons. The decision also clarified the scope of the writ of habeas corpus, emphasizing that it is a remedy for violations of federal law.

Justice Harlan delivered the dissenting opinion in Dold v. United States, arguing that Congress had exceeded its authority under the Constitution by enacting a law which imposed criminal penalties for failing to comply with certain regulations of the Secretary of Agriculture. He argued that such laws were beyond Congress' power to regulate interstate commerce and thus violated due process rights guaranteed by the Fifth Amendment. Furthermore, he noted that there was no evidence presented at trial indicating any connection between Dold's failure to comply with these regulations and any effect on interstate commerce or public health or safety. As such, Justice Harlan concluded that this law was unconstitutional as it deprived citizens of their liberty without due process of law and should be overturned.