In the Stanley v. Schwalby case of 1895, the U.S. Supreme Court ruled in favor of defendant Schwalby, a military officer who had been sued by plaintiff Stanley for assault and battery during an arrest on a military reservation. The court held that as long as an officer is acting within his jurisdiction and does not use excessive force or act maliciously, he cannot be held liable for injuries sustained by someone resisting arrest. This decision was based on common law principles which protect officers from liability when performing their duties under reasonable belief they are lawful orders even if later found to be incorrect. The ruling emphasized the importance of maintaining order within military reservations and protecting officers who carry out their duties in good faith.

In the dissenting opinion for Stanley v. Schwalby, Justice Brewer argued that the case should not have been dismissed on jurisdictional grounds. He believed that there was a federal question involved in this case because it concerned an act of Congress and its interpretation - specifically, whether or not certain military orders were authorized by Congress. Therefore, he contended that the Supreme Court had jurisdiction to hear this appeal from a state court decision. Furthermore, Justice Brewer disagreed with the majority's view that no rights under U.S law were denied by Michigan courts' decisions; instead, he asserted that if these military orders are found unlawful then Stanley’s detention would be illegal too which is indeed a violation of his rights under U.S laws.