The Grace Girdler was a Supreme Court case that dealt with the issue of whether a state court could issue a writ of habeas corpus to a prisoner held in a federal prison. The case arose when a prisoner, Grace Girdler, was held in a federal prison in the state of Georgia. Girdler sought a writ of habeas corpus from the state court, arguing that she was being held in violation of her constitutional rights. The Supreme Court held that the state court did not have the authority to issue a writ of habeas corpus to a prisoner held in a federal prison. 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 be allowed to interfere with the federal government's power to protect this right. The Court's decision in this case established the principle that state courts do not have the authority to issue writs of habeas corpus to prisoners held in federal prisons.

In the case of The Grace Girdler, Justice Field delivered a dissenting opinion. He argued that Congress had no authority to pass laws regulating pilotage on navigable waters within state boundaries. According to him, this was an issue for states to decide and regulate as they saw fit. Furthermore, he believed that if Congress were allowed to pass such laws it would be in violation of the Tenth Amendment which reserves all powers not delegated by the Constitution exclusively for the states or people. In addition, he noted that there was nothing in Article I Section 8 of the Constitution granting Congress power over pilotage regulations within state boundaries and thus any attempt by them to do so would be unconstitutional. Finally, Justice Field concluded his dissent with a warning about allowing too much federal control over matters traditionally left up to individual states: “The tendency is strong towards centralization; but we should guard against its progress beyond what is necessary for national purposes”