Maxwell v. Stewart 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, Maxwell, was held in a federal prison in the state of Tennessee. Maxwell 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 conditions of the detention. The Court's decision in Maxwell v. Stewart established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons. This decision has been cited in numerous subsequent cases, and has been used to support the principle that state courts cannot interfere with the federal government's authority to imprison individuals.

Justice Field delivered the dissenting opinion in Maxwell v. Stewart, arguing that the majority had misapplied existing law to reach its conclusion. He argued that under prior Supreme Court precedent, a party could not be held liable for damages resulting from an act of Congress unless it was done with malicious intent or gross negligence. In this case, he believed there was no evidence of either malice or gross negligence on behalf of the defendant and thus they should not have been found liable for any damages caused by their actions. Furthermore, Justice Field noted that even if liability were established in this case it would set a dangerous precedent as many other acts of Congress may cause similar damage without any fault on behalf of those affected by them and yet they would still be held responsible for such losses due to this ruling.