Opinion of the Court
acknowledged Watkins and took pains to reconcile its holding with the traditional rule. See 100 U. S., at 375–377. And, when asked to review convicting courts’ substantive errors of statutory law in habeas corpus proceedings, this Court consistently held that it could not do so.[1] It was not
- ↑ See, e.g., Knewel v. Egan, 268 U. S. 442, 446 (1925) (“It is fundamental that a court upon which is conferred jurisdiction to try an offense has jurisdiction to determine whether or not that offense is charged or proved”); In re Gregory, 219 U. S. 210, 213 (1911) (“[W]e are not concerned with the question whether the information was sufficient or whether the acts set forth in the agreed statement constituted a crime, that is to say, whether the court properly applied the law, if it be found that the court had jurisdiction to try the issues and to render the judgment”); In re Eckart, 166 U. S. 481, 483 (1897) (explaining that habeas would not offer relief from “a trial and conviction upon an indictment, the facts averred in which are asserted to be insufficient to constitute an offence against the statute claimed to have been violated”); Ex parte Yarbrough, 110 U. S. 651, 654 (1884) (“Whether the indictment sets forth in comprehensive terms the offence which the statute describes and forbids … is in every case a question of law … within [the trial court’s] jurisdiction”); Ex parte Parks, 93 U. S. 18, 20–21 (1876) (“It would be an assumption of authority for this court, by means of the writ of habeas corpus, to review every case in which the defendant attempts to controvert the criminality of the offence charged in the indictment”).
Ignoring this authority, Justice Jackson’s dissent cites a handful of inapposite cases to suggest that 19th-century American courts would have treated claims such as Jones’ as cognizable in habeas. See post, at 31–32, n. 19, 34, 36–37, n. 25. Grant v. United States, 58 F. 694 (CA9 1893), was a case on a writ of error, not habeas corpus. Ex parte D’Olivera, 7 F. Cas. 853 (No. 3,967) (CC Mass. 1813), was another justice-of-the-peace case. Ex parte Randolph, 20 F. Cas. 242, 254 (No. 11,558) (CC Va. 1833), involved detention unsupported by any “judgment” or “judicial process” whatsoever. United States v. Bainbridge, 24 F. Cas. 946 (No. 14,497) (CC Mass. 1816), involved a collateral attack on a sentence imposed by a naval court martial; Justice Story’s opinion turned on the validity of the petitioner’s contract of enlistment, which, in turn, went to the court martial’s jurisdiction. Id., at 949–952; see also Ex parte Watkins, 3 Pet 193, 209 (1830); Wise v. Withers, 3 Cranch 331, 337 (1806). Ex parte Bollman, 4 Cranch 75 (1807), relieved two alleged traitors from
re-try the issues, whether of law, constitutional or otherwise, or of fact.” Id., at 429 (emphasis added).
