## Facts

- Sherman M. Booth, a Wisconsin abolitionist editor, was arrested for conduct connected to the rescue of an alleged fugitive slave, Joshua Glover, from federal custody.
- Booth was held under federal process pursuant to the Fugitive Slave Act of 1850.
- A Wisconsin state judge issued a writ of habeas corpus and ordered Booth released from federal custody.
- Booth was later indicted, convicted, and sentenced in the U.S. District Court for the District of Wisconsin for violating the Fugitive Slave Act.
- The Wisconsin Supreme Court granted habeas relief, declared the Fugitive Slave Act unconstitutional, and ordered Booth discharged, effectively purporting to invalidate federal proceedings and judgment.
- The United States and the U.S. marshal obtained writs of error to review the Wisconsin Supreme Court’s judgments.

## Issues

1. Whether a state court may issue habeas corpus to discharge a prisoner held by a federal officer under federal authority.
2. Whether a state supreme court may declare a federal statute unconstitutional and thereby nullify federal court proceedings and judgments.
3. Whether the U.S. Supreme Court has appellate authority to review a state court judgment that rejects federal authority in a case arising under federal law.

## Decision

- The U.S. Supreme Court unanimously reversed the Wisconsin Supreme Court.
- The Court held that state courts have no authority to issue habeas writs that operate within the sphere assigned to the United States or to discharge persons held under federal process.
- The Court held that a federal marshal served with a state habeas writ must return the federal authority under which he holds the prisoner, but must not obey state process that would interfere with federal custody.
- The Court held that the U.S. Supreme Court has appellate jurisdiction to review state court judgments in cases arising under the Constitution and laws of the United States.
- The Court upheld the constitutionality of the Fugitive Slave Act of 1850 and recognized federal authority to arrest, commit, try, and punish offenses under it.
- The Court held that the federal district court had exclusive jurisdiction over the federal offense and that its proceedings and judgment could not be reexamined and set aside by another tribunal.

## Legal Principles

- State judicial process has no force beyond the sovereignty that confers it; state habeas cannot control federal detention under federal law.
- Federal officers executing federal process must obey federal authority even when confronted with contrary state judicial commands.
- Federal law and federal judicial determinations are supreme within the federal sphere; state courts may not nullify federal statutes or federal judgments.
- The U.S. Supreme Court may review state court judgments that deny federal rights or reject federal authority in cases arising under federal law.
- Where Congress assigns jurisdiction over federal offenses to federal courts, state courts may not collaterally invalidate those federal proceedings through habeas corpus.

## Conclusion

The Court reaffirmed federal judicial supremacy by holding that state courts cannot use habeas corpus to release federal detainees or invalidate federal judgments, and it sustained federal enforcement authority under the Fugitive Slave Act of 1850.


Ableman v. Booth, 62 U.S. (21 How.) 506 (1859)