In the case of In re Manning, 1890, the petitioner was a U.S. Marshal who had been held in contempt by a lower court for failing to execute an order. The Supreme Court ruled that it did not have jurisdiction to review such cases on writs of habeas corpus or certiorari because they were considered final judgments under federal law at that time. This decision reinforced the principle of judicial independence and affirmed that high courts cannot interfere with lower courts' decisions unless there is some violation of constitutional rights or legal procedure. It also highlighted how important it is for officers of the court to respect and follow orders from judges, as failure to do so can lead to serious consequences like being found in contempt.

The dissenting opinion in the case of In re Manning, 1890, argued that the petitioner should not be held in contempt for refusing to answer questions before a grand jury. The justice believed that compelling an individual to testify against themselves violated their Fifth Amendment rights. They contended that this protection extended beyond criminal trials and applied equally to grand jury proceedings. Furthermore, they disagreed with the majority's interpretation of immunity statutes, arguing these did not adequately protect individuals from self-incrimination as they only prevented future prosecution based on compelled testimony but did not prevent its use altogether. Thus, according to them, forcing Manning to testify would still expose him potentially damaging consequences despite any statutory protections offered by immunity laws.