Court held that the composition of a grand jury (i.e. whether an alien sat) could not be so reviewed. But, in several cases, the Court did find original habeas jurisdiction and reached the merits. In Ex parte Karstendick (1876), the Court held that a federal court had no statutory authority to sentence a defendant to hard labor at a state prison outside of its territorial jurisdiction. In Ex parte Jackson (1877), the Court considered several constitutional issues, including the Postal Power, the application of the First Amendment to mail-order gambling, and the application of the Fourth Amendment's warrant requirement to the mail. In Ex parte Lothrop (1886), the Court found that the Arizona territorial courts were properly constituted. In In re Sawyer (1888), the Court granted the writ to state judges imprisoned by a federal judge for violating an injunction. In Ex parte Clarke (1879), the Court held that a habeas petition filed with a single justice would be referred to the entire Court. State confinement In Ex parte Royall (1886), for the first time, the Court was petitioned to grant an original writ of habeas corpus to a prisoner in state custody. The Court held that, assuming it had such a power, it should not be exercised except in special circumstances: It is sufficient to say that if this court has power, under existing legislation, and upon habeas corpus, to discharge the petitioner, who is in custody under the process of a state court of original jurisdiction, for trial on an indictment charging him with an offense against the laws of that state,-upon which it is not necessary to express an opinion,-such power ought not, for the reasons given in the other cases just decided, to be exercised in advance of his trial. In Ex parte Fonda (1886), the Court denied leave to file an original habeas petition, citing Royall. In Ex parte Ayers (1887), the Court denied a state-prisoner petition on the merits, finding that the state tax law did not violate the Contracts Clause. Habeas appeals During the Chase Court-era, Congress had stripped the Court of the authority to hear appeals from habeas petitions in the circuit courts. In Ex parte Royall (1884), the Waite Court dismissed such an appeal, holding that the jurisdiction had never been restored. But, the Court did retain jurisdiction over habeas appeals in a limited subset of cases. For example, in Wales