In the 1932 case Ex Parte La Prade, the United States Supreme Court ruled that a federal court has no jurisdiction to issue a writ of habeas corpus when it is directed at state officials for actions taken under state law. The petitioner, La Prade, was an attorney who had been disbarred by Arizona courts and subsequently imprisoned for practicing law without a license. He sought relief from his imprisonment through federal habeas corpus proceedings on constitutional grounds. However, the Supreme Court held that since he was not in custody pursuant to any order or judgment of a federal court but rather due to violation of state laws enforced by state officers, there was no basis for invoking federal jurisdiction. This decision reinforced principles of federalism and limited intervention by Federal Courts into State matters.

In the dissenting opinion for Ex Parte La Prade, it was argued that the court had overstepped its jurisdiction. The dissenting justices believed that this case should have been handled by a lower court first before reaching the Supreme Court. They also disagreed with how quickly and abruptly the majority decided to issue a writ of habeas corpus in favor of La Prade without giving sufficient consideration to all aspects of his case. Furthermore, they contended that there were other legal remedies available to La Prade which he did not exhaust before petitioning for habeas corpus relief at the Supreme Court level. In essence, they felt that due process was not properly followed and criticized their colleagues' decision as being hasty and premature.