Gibbs v. Diekma 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, John Gibbs, was held in a federal prison in the state of Ohio. Gibbs sought a writ of habeas corpus from the state court, claiming that he was being held in violation of his constitutional rights. The state court granted the writ, and the federal government appealed the decision to the Supreme Court. 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 remedy, 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 remedy that could only be used to challenge the legality of a person's detention, and not to challenge the conditions of the detention. In conclusion, 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 remedy, and that the state court did not have the power to interfere with the federal government's authority to imprison individuals.

In Gibbs v. Diekma, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a non-resident against another non-resident in which both parties were citizens of different states and neither party resided in the forum state. The majority opinion held that such jurisdiction did not exist under the Constitution or any federal statute. Justice Field dissented from this decision, arguing that it would be unfair for two individuals who are citizens of different states to have no recourse when one wrongs the other if they cannot bring suit in either's home state due to lack of residence there. He argued that allowing suits between nonresidents with diverse citizenship is necessary for justice and fairness, especially since many disputes arise out of business transactions conducted across multiple jurisdictions. Furthermore, he noted that Congress has passed statutes granting courts authority to hear cases involving diversity of citizenship even when none of the parties reside within their district; thus implying congressional approval for such actions as well as recognition by Congress itself regarding its importance and necessity.