In Bryan v. Pinney (1895), the U.S Supreme Court was tasked with determining whether a federal court in one state could issue an injunction to prevent proceedings in a state court of another state. The case arose from conflicting claims over land located in Kansas, where both parties initiated separate lawsuits - one party filed suit in Ohio and the other party filed suit directly related to the same property dispute but within Kansas jurisdiction. The plaintiff sought an injunction from the federal court against further proceedings by defendants before any courts except for that of Ohio's jurisdiction. However, this request was denied on appeal as it violated Section 720 Revised Statutes which prohibits such actions unless expressly authorized by Congress or when necessary for aid of its jurisdiction or protection of its judgments. The Supreme Court upheld this decision stating that no act of Congress had given express authority to restrain proceedings in State Courts and therefore, under Section 720 Revised Statutes, Federal Courts do not have power to enjoin persons from proceeding with cases pending at State Courts.

In the dissenting opinion for Bryan v. Pinney, 1895, it was argued that the majority's decision to uphold a lower court ruling - which held that an individual could not claim ownership of land in Indian Territory if they were non-Indian and had no government permission - was incorrect. The dissenting justices believed this interpretation of law unfairly penalized individuals who purchased lands from Native Americans in good faith and with their consent. They contended that such transactions should be considered valid as long as there is mutual agreement between both parties involved. Furthermore, they expressed concern over how this ruling might affect future property rights disputes involving Native American lands.