In the case of Alabama et al. v. United States et al., 1962, the state of Alabama and several other southern states challenged the constitutionality of certain sections within Title III of the Civil Rights Act (1957). These sections allowed for federal intervention in cases where African American citizens were denied their right to vote due to discriminatory practices such as literacy tests or poll taxes. The Supreme Court ruled unanimously against Alabama, upholding that these provisions did not infringe upon states' rights under Tenth Amendment nor violate principles of federalism because they were a legitimate exercise by Congress to enforce Fifteenth Amendment's prohibition on racial discrimination in voting. This decision was significant as it affirmed federal government’s authority to intervene in state affairs when necessary to protect constitutional rights, particularly those related with voting.

In the dissenting opinion for Alabama et al. v. United States et al., Justice Harlan argued that the Supreme Court had overstepped its jurisdiction by intervening in a matter of state reapportionment, which he believed should be left to Congress or the states themselves. He contended that there was no constitutional basis for federal courts to interfere with how states allocated their legislative districts and warned against judicial activism, cautioning it could lead to an imbalance of power between different branches of government and levels of governance. Furthermore, he expressed concern about potential political implications if federal courts were allowed to dictate state apportionment policies without clear constitutional guidance or precedent.