Smith v. Nichols 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, Smith, was held in a federal prison in Arkansas. Smith filed a petition for a writ of habeas corpus in the state court, arguing that he was being held in violation of the Constitution. The state court granted the writ and ordered Smith's release. 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 the writ of habeas corpus. The Court reasoned that the 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 individuals. The Court also noted that the writ of habeas corpus was a fundamental right, and that the state court should not interfere with the federal government's power to protect this right. The Court's decision in Smith v. Nichols established that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons. The decision also reaffirmed the federal government's power to protect the fundamental right of habeas corpus.

Justice Field delivered the dissenting opinion in Smith v. Nichols, arguing that the majority's decision was contrary to established precedent and would lead to a dangerous expansion of federal power. He argued that Congress had no authority under Article III of the Constitution to create a court with jurisdiction over cases involving private parties from different states, as this was an issue reserved for state courts. Furthermore, he noted that if such a court were created it would be unconstitutional because it did not have any appellate review by either the Supreme Court or another circuit court. Finally, Justice Field warned against allowing Congress too much latitude in creating new courts without proper oversight and checks on their powers; otherwise they could become "dangerous engines of oppression."