Garfield 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 held in a state prison. The case arose when a prisoner, Garfield, was held in a state prison in California and sought a writ of habeas corpus from a federal court. The federal court denied the writ, and Garfield appealed to the Supreme Court. The Supreme Court held that the federal court did not have the power to issue a writ of habeas corpus to a prisoner held in a state prison. The Court reasoned that the power to issue a writ of habeas corpus was a power reserved to the states under the Tenth Amendment. The Court also noted that the federal government had no authority to interfere with the state's power to imprison its citizens. The Court's decision in Garfield v. United States established that the federal government could not interfere with the states' power to imprison their citizens. This decision has been cited in numerous cases since then, and it remains an important precedent in the area of federalism.

Justice Field delivered the dissenting opinion in Garfield v. United States, arguing that Congress did not have the power to pass a law requiring citizens to pay taxes on income from real estate investments. He argued that this was an unconstitutional exercise of Congressional authority because it violated the Fifth Amendment's protection against double taxation and constituted a taking of private property without just compensation. Furthermore, he argued that such a tax would be oppressive and unjust since it would disproportionately burden those who had invested their money in real estate rather than other forms of investment. In conclusion, Justice Field believed that Congress should not be able to impose such an unfair tax on individuals' incomes from real estate investments as they are already taxed when they purchase or sell land or buildings.