In Bronson v. La Crosse and Milwaukie Railroad Company, the Supreme Court of the United States held that a state court could not enjoin an act of Congress in order to prevent it from being carried out. The case arose when two railroad companies sought to build a bridge across the Mississippi River at La Crosse, Wisconsin. The plaintiffs argued that this would interfere with their navigation rights on the river and asked for an injunction against construction of the bridge. However, Congress had already passed legislation authorizing construction of such bridges over navigable waters without requiring permission from states or individuals whose property might be affected by them. Therefore, since Congress had acted within its constitutional authority in passing this law, it was beyond any state court's power to issue an injunction preventing its enforcement. As such, the Supreme Court affirmed dismissal of plaintiff's complaint by lower courts and denied their request for injunctive relief against building a bridge over navigable waters authorized by federal law

In Bronson v. La Crosse and Milwaukie Railroad Company, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by citizens of one state against citizens of another in which the amount in controversy exceeded $500. The majority opinion held that it did not have such jurisdiction, as this would be contrary to Article III of the Constitution. However, Justice Field dissented from this decision on two grounds: firstly, he argued that Congress had given states authority to exercise concurrent jurisdiction with federal courts; secondly, he argued that even if Congress had not done so explicitly then they should be assumed to have done so implicitly due to their silence on the matter for many years prior. He concluded by stating his belief that denying states power over cases involving more than $500 would lead them into "utter helplessness" when dealing with large-scale disputes between citizens of different states.