Strong v. United States was a United States Supreme Court case that addressed the issue of whether a federal court had the authority to issue a writ of habeas corpus to a prisoner who was being held in a state prison. The case arose when a prisoner, William Strong, was convicted of murder in the state of Pennsylvania and sentenced to life in prison. Strong then filed a petition for a writ of habeas corpus in the United States District Court for the Eastern District of Pennsylvania, arguing that his conviction was unconstitutional. The District Court denied the petition, and Strong appealed to the Supreme Court. The Supreme Court held that the District Court did not have the authority to issue a writ of habeas corpus to a prisoner held in a state prison. The Court reasoned that the writ of habeas corpus was a remedy available only to prisoners held in federal custody, and that the District Court lacked the power to interfere with the state's criminal justice system. The Court also noted that the writ of habeas corpus was a remedy of last resort, and that Strong had failed to exhaust all other available remedies before seeking relief from the federal court. The Court's decision in Strong v. United States established that federal courts do not have the authority to issue writs of habeas corpus to prisoners held in state prisons. This decision has been cited in numerous subsequent cases, and remains an important precedent in the area of federal habeas corpus law.

Justice Field delivered the dissenting opinion in Strong v. United States, arguing that Congress had exceeded its power under the Constitution when it passed a law allowing for criminal prosecution of individuals who failed to pay taxes on distilled spirits. He argued that this was an issue which should be regulated by state governments rather than federal government and thus fell outside of Congress' authority to legislate. Furthermore, he noted that such laws were not necessary as states already had their own tax systems in place and these could have been used instead of creating a new federal system. Justice Field concluded his dissent by stating that if Congress wanted to impose taxes on distilled spirits then they should do so through constitutional means rather than passing unconstitutional legislation which would lead to potential abuse from overzealous prosecutors.