Marsh v. Whitmore 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 Marsh, was held in a federal prison in California. Marsh sought a writ of habeas corpus from the California Supreme Court, claiming that he was being held in violation of the Constitution. The California Supreme Court granted the writ, and the United States Supreme Court was asked to decide whether the state court had the authority to do so. The Supreme Court held that the state court did not have the authority to issue the writ of habeas corpus. The Court reasoned that the writ of habeas corpus was a federal remedy, and that the state court did not have the power to issue such a writ. 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 that the state court did not have the power to determine the legality of a federal detention. 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 issue such a writ. 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 that the state court did not have the power to determine the legality of a federal detention.

Justice Field delivered the dissenting opinion in Marsh v. Whitmore, arguing that the majority's decision was wrongfully based on a misinterpretation of California law. He argued that under California law, an unincorporated association could not own land and thus had no legal capacity to sue or be sued. As such, he believed it was improper for the court to grant relief to Whitmore since she did not have standing as a party in this case. Furthermore, Justice Field noted that even if Whitmore did have standing as a party in this case, her claim would still fail because there were other parties who held superior title claims over her own and thus should prevail regardless of any equitable considerations which may apply here. Ultimately then, Justice Field concluded by asserting his belief that the Court should reverse its ruling and dismiss Whitmore's suit due to lack of jurisdiction over her claim given its interpretation of California law at issue here.