In the case of In re Woods, Petitioner (1891), the U.S. Supreme Court was asked to consider whether a lower court had erred in its decision to deny a writ of habeas corpus for an individual who had been convicted and sentenced by a military commission. The petitioner, Mr. Woods, argued that his conviction should be overturned because he was not part of the military or naval forces at the time of his alleged offense and therefore should not have been tried by a military tribunal. However, after reviewing the facts presented before them, including evidence that showed Mr. Woods was serving as an Indian agent - which is considered part of the army - at Fort Hall Reservation when he committed forgery (the crime for which he was convicted), it led him under jurisdictional purview of martial law during wartime conditions with Native American tribes in Idaho Territory where civil courts were non-functional due to hostilities; hence justifying trial by Military Commission instead civilian courts.The Supreme Court upheld this view and ruled against Mr.Woods' petition stating that there existed no error on part of lower court's judgement denying Habeas Corpus relief.

The dissenting opinion in the case of In re Woods, Petitioner (1891) argued that the majority's decision to deny a writ of habeas corpus was incorrect. The dissent contended that there were no legal grounds for holding the petitioner in custody and thus, his detention was unlawful. It further stated that it is not within the jurisdiction of any court or judge to imprison an individual without just cause. The dissent also criticized the majority's interpretation of extradition laws, arguing they had been misapplied in this case. They believed these laws should be used as tools for justice rather than instruments for oppression and arbitrary power over individuals' liberties.