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Ming & Another v. Woolfolk

• 1885 • 116 U.S. 599 • Waite Court
Ming & Another v. Woolfolk 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 two Chinese immigrants, Ming and another, were arrested and convicted of larceny in the state of California. They were sentenced to serve time in a federal prison. The two men then filed a petition for a writ of habeas corpus in the state court, arguing...Open Case
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Chief Waite Court
Term: 1885
Docket: 116
116 U.S. 599
6 S. Ct. 493
29 L. Ed. 740
1886 U.S. LEXIS 1803

Ming & Another v. Woolfolk

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Opinion Summary
AI Abstract

Ming & Another v. Woolfolk 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 two Chinese immigrants, Ming and another, were arrested and convicted of larceny in the state of California. They were sentenced to serve time in a federal prison. The two men then filed a petition for a writ of habeas corpus in the state court, arguing that their conviction was unconstitutional. The state court granted the writ and ordered the federal prison to release the two men. The federal government then appealed the decision to the Supreme Court, arguing 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 Supreme Court agreed with the federal government, ruling 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 power 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 fundamental right and that the federal government had the power to protect this right.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Ming & Another v. Woolfolk, a case involving an appeal from the Supreme Court of Mississippi. The appellants argued that they had been denied their right to due process under the Fourteenth Amendment when a jury awarded damages for trespass on land owned by them but held by another party as trustee. Justice Field disagreed with this argument and stated that it was not necessary for there to be any notice or hearing before judgment could be rendered against trustees who were holding property in trust for others; rather, he believed that such judgments should be based solely upon evidence presented at trial and determined according to established legal principles. He further noted that if parties felt aggrieved after judgment had been entered against them, then they could always seek redress through other means such as appeals or writs of error coram nobis. In conclusion, Justice Field expressed his belief that no constitutional rights had been violated in this particular case and thus affirmed the decision of the lower court which found in favor of Woolfolk over Ming & Another.

Opinion written by Justice WBWoods
Decided: Feb 01, 1886
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