United States v. Mitchell 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 prisoner who was being held in a state prison. The case involved a man named Mitchell who had been convicted of a crime in the state of Georgia and was serving a sentence in a state prison. The Supreme Court held that the federal court did not have the authority to issue a writ of habeas corpus to a prisoner who was being held in a state prison. The Court reasoned that the writ of habeas corpus was a remedy that was available only to prisoners who were being held in federal custody. The Court also noted that the writ of habeas corpus was a remedy that was available only to prisoners who were being held in violation of the Constitution or laws of the United States. The Court concluded that since Mitchell was being held in a state prison, the federal court did not have the authority to issue a writ of habeas corpus. The Court also noted that the writ of habeas corpus was not available to prisoners who were being held in state custody. The Court held that the writ of habeas corpus was a remedy that was available only to prisoners who were being held in federal custody.

Justice Field delivered the dissenting opinion in United States v. Mitchell, arguing that the majority had misapplied a prior Supreme Court decision to reach its conclusion. He argued that the court should not have relied on an earlier case involving a different set of facts and circumstances to decide this one. Instead, he argued that they should have looked at the specific language of Congress' act granting land for educational purposes and determined whether or not it applied in this situation. In his view, Congress did not intend for their grant to apply when there was no schoolhouse built upon it as required by law; thus, he believed that Mitchell's claim was invalidated by this fact alone without any need to rely on precedent from another case with distinct facts and issues.