In the case of Alfred L. Snapp & Son, Inc., et al. v. Puerto Rico ex rel. Barez, Secretary of Labor and Human Resources (1981), the Supreme Court ruled that Puerto Rico had standing to sue on behalf of its citizens under parens patriae doctrine for alleged violations by Virginia apple growers who were accused of discriminating against Puerto Rican workers in favor of temporary foreign workers from Jamaica and other countries in their hiring practices for seasonal employment opportunities. The court held that a State has a quasi-sovereign interest in the health and well-being—both physical and economic—of its residents in general which allows it to bring suit on their behalf even if it is not directly harmed or affected itself.

In the dissenting opinion for Alfred L. Snapp & Son, Inc., v. Puerto Rico ex rel. Barez, Justice Powell argued that Puerto Rico did not have standing to bring a suit against Virginia apple growers on behalf of its migrant workers under the Wagner-Peyser Act and other federal statutes. He contended that these laws were designed to protect individual rights rather than those of a commonwealth or state entity like Puerto Rico. Furthermore, he asserted that allowing such suits could lead to an influx of litigation from states seeking redress for perceived injuries suffered by their citizens in another jurisdiction - something he believed was contrary to the principles of federalism and potentially disruptive to interstate relations.