In the case of The People of the State of New York ex rel. Lieberman v. Van De Carr, Warden (1905), the U.S Supreme Court was asked to consider whether a state court's decision could be reviewed by a federal court in relation to an extradition matter. The petitioner, Mr. Lieberman, had been arrested in New York on charges from Missouri and sought habeas corpus relief arguing that his arrest violated his constitutional rights as he claimed there was no evidence supporting Missouri’s charge against him for embezzlement. However, both the lower courts and Supreme Court ruled against him stating that it is not within their jurisdiction to review or overturn decisions made by state courts regarding extradition matters unless there are exceptional circumstances such as lack of jurisdiction or violation of constitutional rights which were not found here.

In the dissenting opinion for The People of the State of New York ex rel. Lieberman v. Van De Carr, Warden, 1905 case, it was argued that there were significant procedural errors in how Mr. Lieberman's trial was conducted which should have led to a reversal of his conviction and a new trial being ordered. It was pointed out that evidence used against him had been obtained illegally and thus should not have been admissible in court; this included both physical evidence and testimonies from witnesses who had allegedly been coerced into testifying against him under threat of punishment if they did not comply with prosecutors' demands. Furthermore, it was contended that Mr. Lieberman's right to due process had also been violated because he wasn't given adequate time or resources to prepare an effective defense strategy before his trial began - something which is guaranteed by the Constitution as part of every citizen's fundamental rights when facing criminal charges.