Gunnell v. Bird 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 held in a federal prison. The case arose when a prisoner, William Gunnell, was held in a federal prison in the state of Virginia. Gunnell sought a writ of habeas corpus from the state court, claiming that he was being held in violation of the Constitution. 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 prerogative, and that the state court did not have the authority to interfere with the federal government's power to imprison individuals. The Court also noted that the writ of habeas corpus was a fundamental right, and that the federal government had the exclusive power to protect this right. 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 prerogative, and that the state court did not have the authority to interfere with the federal government's power to imprison individuals. The Court also noted that the writ of habeas corpus was a fundamental right, and that the federal government had the exclusive power to protect this right.

In Gunnell v. Bird, the Supreme Court of the United States was asked to decide whether a state court had jurisdiction over an action brought by a citizen of one state against another in which it was alleged that the defendant committed fraud while acting as executor for his deceased father's estate. The majority opinion held that since there were no allegations of any act done within the forum state, and since all acts complained of occurred outside its borders, then the court lacked jurisdiction over this matter. In dissent however, Justice Field argued that although no act may have been performed within the forum state itself, if those acts caused injury to property located therein then they could be considered sufficient grounds for exercising jurisdiction under certain circumstances. He further stated that even though Congress has not specifically granted such authority to states yet it should be assumed unless prohibited by some other law or constitutional provision; and he concluded with his belief that nothing in either would prevent them from doing so here.