Douglass v. Lewis 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 Douglass, was held in a federal prison in the District of Columbia. Douglass sought a writ of habeas corpus from the Supreme Court of the District of Columbia, which was denied. Douglass then appealed to the Supreme Court of the United States. 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 prerogative, 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 fundamental right, and that the state court could not interfere with the federal government's exercise of that right. The Court's decision in Douglass v. Lewis established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons. This decision has been cited in numerous subsequent cases, and has been used to support the idea that the federal government has exclusive authority over the imprisonment of individuals.

Justice Field delivered the dissenting opinion in Douglass v. Lewis, a case concerning whether or not an African American man was entitled to damages for false imprisonment and malicious prosecution. Justice Field argued that the plaintiff had failed to prove his claim of malicious prosecution because he did not show any evidence of malice on behalf of the defendant. He further argued that even if there were sufficient evidence presented, it would be impossible to award damages due to lack of precedent in similar cases involving African Americans as plaintiffs. Additionally, Justice Field noted that since this was a state court matter rather than federal court matter, it should have been heard by a jury instead of being decided by judges alone. Ultimately, Justice Field concluded that while he sympathized with the plight faced by African Americans at this time period in history, he felt compelled to dissent from the majority opinion due to lack of legal authority and precedent set forth for such matters at hand.