een federal and
State courts are exposed to other frictions, such as injunctions in one
jurisdiction restraining judicial processes in another, the use of the
writ of _habeas corpus_ by a court of concurrent jurisdiction to release
persons in custody of another, and the refusal by State courts to comply
with orders of the Supreme Court. The relations between federal and
State courts are governed in part by Constitutional Law with respect to
State court interference with the federal courts and State court refusal
to comply with the judgments of federal tribunals, by statutes as
regards interference by federal courts with those of the States, and by
self-imposed rules of comity applied for the avoidance of unseemly
conflicts.

DISOBEDIENCE OF SUPREME COURT ORDERS BY STATE COURTS

The refusal of State courts to make returns on writs of errors issued by
the Supreme Court has already been noted in connection with the
disobedience of the Virginia courts in Martin _v._ Hunter's Lessee[648]
and Cohens _v._ Virginia[649] and in that of the Wisconsin court in
Ableman _v._ Booth.[650] More spectacular disobedience to federal
authority arose out of the Cherokee Indian case involving actions of
Georgia and its courts. In the first of these the Supreme Court had
issued a writ of error to the Georgia Supreme Court to review the
conviction of Corn Tassel for the murder of another Cherokee Indian. The
writ was served, but before a hearing could be held Corn Tassel was
executed on the day originally set for punishment contrary to the
federal law that a writ of error superseded sentence until the appeal
was decided. This action ensued as a result of the legislature's
approval of the governor's policy that he would permit no interference
with Georgia's courts by orders of the Supreme Court and would resist by
force any attempt to enforce them with all the forces at his
command.[651]

Worcester _v._ Georgia

Two years later Georgia renewed its defiance of the Supreme Court in
Worcester _v._ Georgia[652] which involved the conviction of two
missionaries for residing among the Indians without a license. The
Supreme Court reversed the conviction on the ground that the State had
no jurisdiction over the Cherokee reservations and ordered Worcester's
discharge in a special mandate to the superior court of Gwinnett County.
The State court ignored the mandate and once again the governor of the
State announced that he would meet such usurpa