Jouan v. Divoll was a United States Supreme Court case that addressed the issue of whether a state court had the authority to issue a writ of habeas corpus to a prisoner who was being held in a federal prison. The case arose when a prisoner, Jouan, was held in a federal prison in the state of New York. Jouan sought a writ of habeas corpus from the state court, claiming that he was being held in violation of his constitutional rights. 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 remedy, 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 remedy that could only be used to challenge the legality of a prisoner's detention, and not to challenge the conditions of the prisoner's confinement. The Court's decision in Jouan v. Divoll established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons. The decision also clarified the scope of the writ of habeas corpus, and established that it could only be used to challenge the legality of a prisoner's detention, and not to challenge the conditions of the prisoner's confinement.

Justice Field delivered the dissenting opinion in Jouan v. Divoll, a case concerning whether or not an individual could be held liable for damages caused by his negligence while operating a vessel on navigable waters. Justice Field argued that the majority's decision was wrong because it failed to consider the fact that Congress had granted exclusive jurisdiction over such matters to state courts and legislatures. He further noted that if federal courts were allowed to hear cases involving maritime torts, then they would be able to override any decisions made by state governments regarding their own laws and regulations governing navigation on navigable waters within their borders. As such, he concluded that allowing federal courts to have jurisdiction over these types of cases would violate both constitutional principles as well as congressional intent when it comes to regulating interstate commerce.