In Mitchell v. United States, the Supreme Court of the United States was asked to decide whether a federal court had the authority to issue a writ of habeas corpus to a prisoner who was being held in a state prison. The petitioner, Mitchell, was convicted of a crime in the state of Georgia and was sentenced to serve a term of imprisonment in the state prison. He then filed a petition for a writ of habeas corpus in the federal court, claiming that his conviction was unconstitutional. The Supreme Court held that the federal court did not have the authority to issue a writ of habeas corpus to a prisoner who was being held in a state prison. The Court reasoned that the writ of habeas corpus was a remedy available only to those who were in custody of the federal government, and not to those who were in custody of the state. The Court further held that the federal court did not have the power to review the constitutionality of a state court conviction. In conclusion, the Supreme Court held that the federal court did not have the authority to issue a writ of habeas corpus to a prisoner who was being held in a state prison. The Court reasoned that the writ of habeas corpus was a remedy available only to those who were in custody of the federal government, and not to those who were in custody of the state. The Court further held that the federal court did not have the power to review the constitutionality of a state court conviction.

Justice Field wrote the dissenting opinion in Mitchell v. United States, arguing that Congress had exceeded its authority by passing a law allowing for the forfeiture of property used to facilitate a crime. He argued that such laws were not authorized under any clause of the Constitution and thus violated due process rights as guaranteed by the Fifth Amendment. Furthermore, he argued that it was improper for Congress to pass legislation which allowed for criminal punishment without trial or conviction; this would be an infringement on judicial power and could lead to arbitrary punishments being imposed upon citizens without proper legal proceedings taking place first. Justice Field concluded his dissent with an argument against using civil remedies as a means of punishing criminals, stating that "the government should never resort to such measures except when absolutely necessary."