In the 1902 case of Bockfinger v. Foster, the U.S. Supreme Court dealt with a dispute over an unpaid debt between two parties from different states, which raised questions about jurisdiction and federalism. The plaintiff, Bockfinger, was a resident of Texas who sued Foster in Louisiana to recover money owed on a promissory note made out by Foster's deceased husband. However, under Louisiana law at that time (the "prescription" statute), such claims were barred after three years if not pursued within that timeframe; whereas in Texas there was no such limitation period for this type of claim. The question before the court was whether it should apply federal common law or state law to determine whether Bockfinger’s claim had expired due to prescription (statute of limitations). The Supreme Court ruled in favor of applying state laws rather than federal common laws when determining issues related to statutes of limitations on debts because these matters are primarily governed by local policy considerations rather than national ones. Therefore, since Louisiana's prescription statute applied and more than three years had passed without action being taken on the note by Bockfinger prior to filing suit against Mrs.Foster , his claim was dismissed as untimely.

In the dissenting opinion for Bockfinger v. Foster, Justice Harlan argued that the majority's decision was inconsistent with previous rulings of the court and violated principles of federalism. He contended that Louisiana law should govern this case since it occurred within its jurisdiction, not Texas law as determined by the majority. According to him, there was no legal basis for applying Texas laws in a situation where an injury took place on a train traveling through Louisiana but owned by a company based in Texas. The justice also pointed out that under Louisiana law, which requires employers to provide safe workplaces or face liability for injuries sustained due to negligence, Foster would have been entitled to compensation from his employer (Bockfinger). Therefore he disagreed with denying Foster's claim based on an application of foreign state laws rather than those applicable at the location where harm occurred.