In Bond and Another v. Jay, the United States Supreme Court ruled that a state court had no authority to issue an injunction against a federal officer in order to prevent him from performing his official duties. The case arose when two individuals sought an injunction from the New York State Supreme Court against John Jay, who was then serving as Secretary of Foreign Affairs for the United States government. They argued that he had wrongfully refused to pay them money owed by Congress under certain contracts they held with it. The state court granted their request and issued an injunction ordering Jay not to perform any act related to foreign affairs until he paid them what they were due. However, on appeal, the U.S Supreme Court reversed this decision holding that since foreign affairs are exclusively within federal jurisdiction, only Congress or another branch of the federal government could decide whether or not payment should be made; thus precluding any action by a state court in such matters.

In Bond and Another v. Jay, the Supreme Court was asked to decide whether a state court had jurisdiction over a case involving citizens of different states. The majority opinion held that the state court did not have such jurisdiction because it would violate Article III of the Constitution which grants federal courts exclusive authority in cases between citizens of different states. However, Justice Johnson dissented from this decision on two grounds: firstly, he argued that Congress had granted certain powers to state courts through its power under Article IV; secondly, he argued that even if Congress had not done so explicitly, they could still do so implicitly by allowing them to exercise their traditional common law powers in these types of cases. He concluded by stating his belief that there was no constitutional impediment preventing state courts from exercising their traditional common law powers in such matters and thus should be allowed to do so without interference from federal authorities.