v. Whitney (1885), the Court affirmed the Supreme Court of the District of Columbia's denial of a habeas petition on the merits, holding that it had no power to review a navy courts martial. Similarly, in Roberts v. Reilly (1885), the Court affirmed a denial of habeas corpus on the merits, but held that it had jurisdiction to consider such appeals under the Extradition Act. In 1885, Congress restored the authority of the Supreme Court to hear appeals from habeas petitions in the circuit courts. In Ex parte Royall (1886), the first case heard under the new statute, the court affirmed a habeas denial, holding that the lower federal courts had discretion to grant or deny habeas relief while the petitioner had not exhausted potential state court remedies. In Mali v. Keeper of the Common Jail of Hudson County (1887), the Court denied another such appeal, holding that the consular treaty with Belgium had not deprived New Jersey of its power to punish a murder committed on a docked foreign vessel. But, in Baldwin v. Franks (1887), the Court granted the writ on appeal, holding that the Reconstruction-era civil rights crime statute applied only to those who deprived U.S. citizens (and not foreign nationals) of their rights. Certificates of division In Ex parte Tom Tong (1883), the Court held that—under 1872 amendments to the certification procedure, which went into effect during the Chase Court-era—because habeas corpus was a civil proceeding, questions arising in habeas cases could not be certified to the Supreme Court until a final judgment had been entered. In United States v. Hamilton (1883), the Court reaffirmed its earlier holdings that certificates could not issue from motions to quash an indictment. Prerogative writs The Waite Court heard two criminal cases under the prerogative writ of mandamus (habeas corpus is also a prerogative writ). In Virginia v. Rives (1879), the Court used mandamus to order a criminal cases removed to federal court under the civil rights removal statute to be remanded back to state court, finding that the statute did not authorize federal jurisdiction because the bar on African-Americans serving on juries was not codified by statute or state constitution. In Ex parte Wall (1883), the Court denied a writ of mandamus, finding that it was proper to remove an attorney who participated in a lynch mob from a case. Defining federal crimes Bankruptcy fraud In United States v.