 In Ex parte Watkins ( 1830 ) , the Court held that the writ did not lie after a federal criminal conviction even if the indictment failed to state an offense . Three years later , with the same petitioner , in Ex parte Watkins ( 1833 ) , the Court did issue the writ because the petitioner was detained beyond his authorized sentence for non @-@ payment of a fine ; although the Court held that such detention would be permissible under the writ of capias pro fine ( generally , a writ ordering the imprisonment of a defendant until a criminal fine is paid ) , it held that it was not under the writ of capias ad satisfaciendum ( a civil law analog ) . After further proceedings in the D.C. circuit court , Watkins was discharged . 
