Goodwin 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, William Goodwin, was convicted of a crime in the state of Virginia and sentenced to a term of imprisonment. Goodwin then filed a petition for a writ of habeas corpus in the United States Circuit Court for the Eastern District of Virginia, claiming that his conviction was unconstitutional. The Circuit Court denied the petition, and Goodwin appealed to the Supreme Court. The Supreme Court held that the Circuit 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 writ of habeas corpus was a remedy available only to prisoners held in federal custody, and that the Circuit Court did not have the power to interfere with the state's criminal justice system. The Court also noted that the writ of habeas corpus was a remedy of last resort, and that Goodwin had other remedies available to him in the state court system. The decision in Goodwin v. United States established that federal courts do not have the power to issue writs of habeas corpus to prisoners held in state prisons. This decision has been cited in numerous subsequent cases, and has been used to support the principle that federal courts should not interfere with the criminal justice systems of the states.

Justice Field delivered the dissenting opinion in Goodwin v. United States, arguing that the majority's decision was wrongfully based on a misinterpretation of the law. He argued that Congress had not intended to make it illegal for citizens to possess firearms without having first obtained permission from local authorities, as this would be an unconstitutional infringement upon their right to bear arms under the Second Amendment. Furthermore, he contended that even if such a restriction were permissible under federal law, it could only apply within certain limited areas and not throughout all states and territories of the Union. Justice Field concluded by stating his belief that Congress did not intend for its laws regarding firearm possession to extend beyond those areas where they are necessary for public safety or security purposes.