Erwin v. United States was a United States Supreme Court case that dealt with the issue of whether a federal court had the power to issue a writ of habeas corpus to a prisoner who was being held in a state prison. The case arose when a prisoner, Erwin, was convicted of a crime in a state court and sentenced to a term of imprisonment. Erwin 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 Erwin's release from prison. The United States government appealed the decision to the Supreme Court, arguing that the federal court did not have the power to issue the writ of habeas corpus. The Supreme Court agreed with the government, holding that the federal court did not have the power to issue the writ of habeas corpus in this case. The Court reasoned that the writ of habeas corpus was a remedy that was available only in cases where a person was being held in federal custody, and not in cases where a person was being held in state custody. As such, the Court held that the federal court did not have the power to issue the writ of habeas corpus in this case.

Justice Field delivered the dissenting opinion in Erwin v. United States, arguing that the majority's decision was contrary to established precedent and would lead to a dangerous expansion of federal power. He argued that Congress had no authority under the Constitution to pass laws regulating private property rights within state boundaries, as doing so would be an unconstitutional infringement on states' rights. Furthermore, he noted that such regulation could only be accomplished through a constitutional amendment or by obtaining consent from all affected states. Justice Field also pointed out that if Congress were allowed this kind of power it could potentially interfere with other areas traditionally left up to individual states such as taxation and education policy. In conclusion, Justice Field believed allowing Congress this type of control over private property within state borders was not only unconstitutional but also posed serious risks for future generations should similar powers continue unchecked in the future.