Pana v. Bowler 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, Pana, was held in a federal prison in California. Pana sought a writ of habeas corpus from the state court, claiming that he was being held in violation of his constitutional rights. 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 Pana v. Bowler 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 Pana v. Bowler, arguing that the majority had erred in their decision to reverse a judgment of the Supreme Court of California. He argued that under existing law, an appeal from a state court could not be taken to a federal circuit court unless it was based on some claim or right arising under federal laws and treaties. In this case, he noted that there was no such basis for an appeal since all claims were based solely on state law and therefore should have been decided by the Supreme Court of California without interference from any other courts. Furthermore, Justice Field argued that even if there had been grounds for an appeal to a federal circuit court, it would still have been improper because Congress did not provide for appeals from judgments rendered by state supreme courts until after this case arose. Therefore, he concluded that both parties should abide by the original ruling issued by the Supreme Court of California as they were bound to do so at the time when their dispute arose.