United States v. Johnston was a United States Supreme Court case that dealt with the issue of whether a federal court had the authority to issue a writ of habeas corpus to a state prisoner. The case involved a man named Johnston who had been convicted of murder in the state of Tennessee and sentenced to death. Johnston filed a petition for a writ of habeas corpus in the United States Circuit Court for the Eastern District of Tennessee, claiming that his conviction was unconstitutional. The Circuit Court granted the writ and ordered Johnston released from prison. The United States government appealed the decision to the Supreme Court, arguing that the Circuit Court did not have the authority to issue the writ. The Supreme Court agreed, ruling that the Circuit Court did not have the authority to issue the writ because the state court had already ruled on the matter. The Court held that the writ of habeas corpus could only be issued by a federal court if the state court had not already ruled on the matter. The Court also held that the writ could not be used to challenge the constitutionality of a state court's decision.

Justice Field delivered the dissenting opinion in United States v. Johnston, arguing that Congress had no authority to pass a law which would allow for the forfeiture of property without due process of law. He argued that this was an unconstitutional deprivation of property and violated the Fifth Amendment's protection against taking private property without just compensation or due process. Furthermore, he argued that even if Congress did have such power, it could not be used to take away someone's right to their own personal effects as they were protected by common law principles from being taken away arbitrarily. Justice Field concluded his dissent by stating that while there may be instances where forfeitures are necessary and appropriate under certain circumstances, this case was not one of them and thus should not stand as precedent for future cases involving similar issues.