Kirk v. Hamilton 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 held in a federal prison. The case arose when a prisoner, John Kirk, was held in a federal prison in the state of Missouri. Kirk 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 Kirk v. Hamilton 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 Kirk v. Hamilton, arguing that the majority's decision was wrongfully based on a misapplication of California law. He argued that under California law, an executor has no authority to sell real estate without court approval and thus could not have validly sold it to Hamilton as he had done. Furthermore, Justice Field argued that even if such a sale were allowed by state law, it would be voidable at any time due to its lack of consideration or fraudulence. As such, he concluded that the lower court should have granted relief from foreclosure proceedings and restored title back to Kirk since she never received proper notice of them nor did she ever receive payment for her property from Hamilton. In conclusion, Justice Field believed that the majority's ruling was erroneous and should be reversed in favor of granting relief for Kirk against foreclosure proceedings initiated by Hamilton