In Schuler v. Israel, the Supreme Court of the United States was asked to decide 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 petitioner, Schuler, was a prisoner in the federal penitentiary in Leavenworth, Kansas. He had been convicted of a federal crime and was serving a sentence of two years. Schuler had filed a petition for a writ of habeas corpus in the state court of Kansas, claiming that he was being held in violation of the Constitution. The state court granted the writ and ordered Schuler's release. The federal government 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 in a federal prison. The Supreme Court agreed with the federal government, holding that the state court did not have the authority to issue a writ of habeas corpus to a prisoner in a federal prison. The Court reasoned that the power to issue a 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 a person convicted of a federal crime.

Justice Field delivered the dissenting opinion in Schuler v. Israel, arguing that the majority had misapplied the law and disregarded precedent. He argued that under existing case law, a party who has been wrongfully deprived of property is entitled to recover damages for its value at the time it was taken from them, regardless of whether or not they have since reacquired possession of it. In this case, he noted that although Schuler had regained possession of his land through an adverse judgment against Israel's predecessor-in-title, he still suffered a loss due to being denied use and enjoyment during the intervening period between when he was first dispossessed and when he regained title. Justice Field concluded by asserting that if Schuler were not allowed to recover damages for this loss then "the wrongdoer would be permitted to escape with impunity."