Kelly v. Calhoun was a United States Supreme Court case that dealt with 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, William Kelly, was held in a federal prison in Georgia. Kelly sought a writ of habeas corpus from the state court, claiming that he was being held in violation of the Constitution. 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 power to interfere with the federal government's authority 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 person's detention, and not to challenge the merits of the underlying conviction. In conclusion, 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 power to interfere with the federal government's authority to imprison individuals.

Justice Field wrote the dissenting opinion in Kelly v. Calhoun, a case concerning whether or not an individual had the right to sue for damages after being wrongfully arrested and imprisoned. Justice Field argued that individuals do have this right and should be able to seek compensation when they are wronged by government officials. He reasoned that if citizens were denied such rights, then it would give government officers too much power over them with no accountability for their actions. Furthermore, he noted that there was precedent from other states which allowed people to sue for wrongful imprisonment and thus this decision should follow suit as well. In conclusion, Justice Field believed that denying citizens of their right to seek redress against those who violate their civil liberties would create a dangerous imbalance of power between the state and its citizens.