In the case of Ohio ex rel.. Lloyd v. Dollison in 1903, the U.S Supreme Court ruled that a state court's decision could not be reviewed by a federal court if it involved only issues of state law and did not raise any federal questions. The case arose when William H. Lloyd was convicted for embezzlement under Ohio law and sentenced to imprisonment. He filed an application for habeas corpus in the Circuit Court of the United States for the Northern District of Ohio, arguing that his conviction violated his rights under both state and federal constitutions because he had been denied due process as guaranteed by these laws. The circuit court dismissed his application on grounds that it lacked jurisdiction over matters involving purely state law issues; this decision was upheld by the Supreme Court upon appeal. In its ruling, Justice Edward Douglass White emphasized that while lower federal courts have authority to issue writs of habeas corpus, they can do so only within their respective jurisdictions - which does not extend to cases where no violation or infringement upon constitutional rights is alleged.

In the dissenting opinion for Ohio ex rel. Lloyd v. Dollison, it was argued that the court's decision to deny a writ of habeas corpus was incorrect and unjustified. The dissenting justices believed that there were significant issues with how the original trial had been conducted, including questions about whether or not due process had been followed correctly in determining guilt. They also raised concerns about potential violations of constitutional rights, arguing that these should have warranted further investigation by the Supreme Court rather than outright dismissal of the case on procedural grounds as decided by majority ruling.