In the case of Bell et al. v. Hood et al., 1945, the plaintiffs filed a lawsuit against FBI agents for violating their Fourth and Fifth Amendment rights by conducting an unlawful search and seizure operation, as well as using forceful interrogation techniques without due process of law. The District Court dismissed the complaint on grounds that it lacked jurisdiction over such claims under federal question jurisdiction statute (28 U.S.C §1331). However, upon appeal to Supreme Court, it was held that if a plaintiff's claim is based on violation of constitutional rights then federal courts do have subject matter jurisdiction regardless of whether or not those rights were actually violated in this particular instance. Therefore, dismissal at initial stage solely based on lack of jurisdiction was deemed inappropriate; instead court should first determine if there indeed has been any constitutional violation before deciding about its own authority over such matters.

The dissenting opinion in the case of Bell et al. v. Hood et al., argued that the federal courts should not have jurisdiction over claims against FBI agents for alleged violations of constitutional rights, unless there was a clear violation of federal law or if the claim exceeded $3,000 as required by statute at that time. The dissenters believed this would prevent an influx of cases into federal court and maintain its role as a tribunal for serious offenses against federal laws. They also expressed concern about potential abuse from plaintiffs who might exaggerate their claims to meet the monetary threshold for filing in a federal court instead of state courts where they normally belong.