Donovan v. United States was a United States 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 held in a state prison. The case arose when a prisoner, John Donovan, was held in a state prison in Massachusetts after being convicted of a crime in a federal court. Donovan sought a writ of habeas corpus from the federal court, arguing that he was being held in violation of his constitutional rights. The Supreme Court held that the federal court did not have the authority to issue a writ of habeas corpus to a prisoner held in a state prison. The Court reasoned that the writ of habeas corpus was a remedy available only to prisoners held in federal custody, and that the federal court did not have the authority to interfere with the state's power to imprison its own citizens. The Court also noted that the writ of habeas corpus was not available to prisoners held in state prisons, as the writ was intended to protect the rights of federal prisoners. The Court's decision in Donovan v. United States established that the federal court did not have the authority to issue a writ of habeas corpus to a prisoner held in a state prison. This decision has been cited in numerous subsequent cases, and has been used to support the principle that the federal court does not have the authority to interfere with the state's power to imprison its own citizens.

Justice Field delivered the dissenting opinion in Donovan v. United States, arguing that Congress did not have the authority to pass a law allowing for an appeal from a decision of the Commissioner of Internal Revenue. He argued that while Congress had been granted certain powers by Article I, Section 8 of the Constitution, it was limited in its ability to grant appeals and could only do so when specifically authorized by statute or when necessary for carrying out other enumerated powers. In this case, he argued that there was no such authorization and thus any attempt by Congress to allow an appeal would be unconstitutional as it exceeded their power under Article I. Furthermore, Justice Field noted that if such appeals were allowed then they should also apply to decisions made by other executive officers who are similarly appointed with similar duties and responsibilities; however since this is not done then it further shows how arbitrary these laws can be. Ultimately Justice Field concluded his dissent stating “The right which has been claimed here on behalf of taxpayers cannot exist unless conferred upon them either directly or indirectly through some act passed in pursuance of constitutional authority”