In Johnson & Another v. Wilkins, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue a writ of habeas corpus to a federal officer. The case involved a dispute between two former slaves, Johnson and Wilkins, who had been emancipated by the United States government. Johnson had been appointed as a federal officer in the Freedmen's Bureau, while Wilkins had been appointed as a state court judge. Wilkins had issued a writ of habeas corpus to Johnson, ordering him to appear before the state court. Johnson argued that the state court did not have the authority to issue the writ, as he was a federal officer and the writ was issued by a state court. The Supreme Court held that the state court did not have the authority to issue the writ of habeas corpus to a federal officer. The Court reasoned that the writ of habeas corpus was a federal prerogative, and that the state court did not have the authority to issue the writ to a federal officer. The Court also noted that the writ of habeas corpus was a fundamental right, and that the state court should not be allowed to interfere with the federal government's authority to protect the rights of its citizens. The Court concluded that the state court did not have the authority to issue the writ of habeas corpus to a federal officer.

Justice Harlan delivered the dissenting opinion in Johnson & Another v. Wilkins, a case concerning whether or not an African American man born into slavery was considered a citizen of the United States and therefore entitled to sue for his freedom under federal law. Justice Harlan argued that Congress had already declared all persons born in the United States to be citizens regardless of race, and thus it should not matter if someone is born into slavery or free; they are still citizens with rights protected by federal laws. He further argued that since there were no exceptions made for those who were enslaved when this declaration was made, then any person who is currently held as a slave must also be granted citizenship status and its associated rights. Finally, he noted that even though some states may have passed laws denying certain privileges to African Americans based on their race, these state-level restrictions do not supersede national declarations which grant full citizenship status regardless of race.