In Strait v. Laird, the United States Supreme Court ruled in 1971 that a petitioner who is physically present within a federal judicial district and has substantial contacts with it satisfies jurisdictional requirements for habeas corpus purposes, even if he is technically domiciled elsewhere. The case involved Robert Strait, an army reservist from California who was ordered to report for active duty during the Vietnam War but refused on grounds of conscientious objection. He filed a petition for writ of habeas corpus in Indiana where his commanding officer was located but was denied by lower courts due to lack of personal jurisdiction since he wasn't "in custody" there as required by law. However, the Supreme Court reversed this decision stating that physical presence and significant contact were enough to establish personal jurisdiction.

In the dissenting opinion for Strait v. Laird, Justice William O. Douglas argued that the majority's decision was a departure from previous rulings regarding habeas corpus petitions by military personnel. He contended that the court had previously held in cases like Schlanger v. Seamans and Noyd v. Bond that federal courts have jurisdiction to hear such petitions when there is an allegation of unlawful custody or restraint under color of military authority, regardless of whether active duty status has been maintained or not at the time of filing suit. Douglas further pointed out that petitioner Strait was still subject to military control as he could be recalled to active duty at any moment and punished for offenses committed while on inactive reserve status; hence his relationship with the Army wasn't entirely severed. He also criticized how this case was handled procedurally - instead of being decided on its merits after full argument, it was summarily reversed without giving due consideration to important constitutional questions raised about jurisdiction over habeas corpus applications by reservists alleging unconstitutional conduct by their superiors.