Ex parte Rowland 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 federal custody. The case arose when a prisoner, Rowland, was arrested by federal authorities and held in federal custody. Rowland then filed a petition for a writ of habeas corpus in a state court, seeking to be released from federal custody. The federal government argued that the state court did not have the authority to issue the writ, as the federal government had exclusive jurisdiction over the matter. The Supreme Court ultimately held that the state court did not have the authority to issue the writ of habeas corpus. The Court reasoned that the federal government had exclusive jurisdiction over matters involving federal prisoners, and that the state court did not have the authority to interfere with the federal government's authority. The Court also noted that the writ of habeas corpus was a federal remedy, and that the state court did not have the authority to issue such a remedy. As such, the Court held that the state court did not have the authority to issue the writ of habeas corpus to Rowland.

In Ex Parte Rowland, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a non-resident of that state. The majority opinion held that the state court did have such jurisdiction and could proceed with the case. However, Justice Field dissented from this decision on two grounds. First, he argued that under existing law it was clear that states were not allowed to exercise personal jurisdiction over non-residents in cases where no cause of action arose within their borders or when there was no other connection between them and the defendant besides his residence outside of their boundaries. Second, he noted that if states were allowed to do so then they would be able to interfere with citizens’ rights without any due process protections since those individuals would not be present in order to defend themselves against these claims. Ultimately, Justice Field concluded that allowing such actions would lead only “to confusion and injustice” and should therefore be prohibited by law as it is contrary both “the spirit of our institutions” as well as established legal precedent regarding jurisdictional limits for courts across different states