In the case of In re McCauley (1896), the U.S. Supreme Court ruled that a federal court did not have jurisdiction to issue a writ of habeas corpus for a prisoner held under state authority unless it was shown that the state court had no jurisdiction over him or her, or if there were exceptional circumstances where justice could not be served without intervention from federal courts. The petitioner, McCauley, was convicted in an Illinois state court and sought relief from his conviction by applying for a writ of habeas corpus in federal court on grounds that he had been denied due process rights under the Fourteenth Amendment. However, since he failed to show any lack of jurisdiction on part of the state court or any extraordinary circumstance warranting interference by Federal authorities into State matters, his application was dismissed.

In the dissenting opinion for In re McCaully, the justice argued that the court majority had overstepped its boundaries by interpreting a federal statute in such a way as to limit an individual's right to apply for and receive a passport. The justice contended that this interpretation was not only inconsistent with previous rulings but also infringed upon personal liberties protected under U.S. law. Furthermore, he expressed concern about potential abuses of power if government officials were given unchecked authority to deny passports based on their own discretion or biases. He believed that any restrictions on issuing passports should be clearly defined by Congress rather than left up to subjective interpretations by courts or bureaucrats.