In the 1991 case of Carol Ankenbrandt v. Jon A. Richards and Debra Kesler, the U.S Supreme Court clarified the scope of domestic relations exception to federal jurisdiction. The plaintiff, Carol Ankenbrandt, acting as next friend and mother of L.R. and S.R., sued her ex-husband (Richards) and his new wife (Kesler), alleging that they had sexually abused her children during visitations after their divorce was finalized in a state court. She sought damages under federal tort law for violation of civil rights among other claims. The district court dismissed the suit based on "domestic relations" exception which traditionally excludes cases involving divorce, alimony or child custody from federal courts' jurisdiction due to their intimate nature better suited for state courts’ expertise. However, upon appeal by Ankenbrandt,the Supreme Court held that this exception does not apply when actual harm is alleged against minors within a family unit but rather only applies to suits seeking divorce, alimony or child custody decrees.The ruling thus allowed such cases with allegations beyond mere domestic disputes into Federal Courts if they meet other criteria for Federal Jurisdiction.

In the dissenting opinion for Ankenbrandt v. Richards, Justice Blackmun argued that the majority's interpretation of domestic relations exception was too narrow and failed to consider its historical context. He contended that this exception should not be limited only to divorce, alimony, and child custody disputes but also extend to cases involving domestic violence or abuse within a family setting. The justice believed that state courts are better equipped than federal courts in handling such sensitive issues due to their familiarity with local conditions and social norms. Furthermore, he expressed concern over potential jurisdictional conflicts between state and federal courts if they were both allowed to adjudicate on similar matters simultaneously. In his view, allowing federal intervention in these types of cases could undermine the authority of state court decisions as well as disrupt ongoing proceedings at the local level.