In the case of Campbell, Commissioner of Agriculture of Georgia, et al. v. Hussey et al., 1961, the U.S Supreme Court ruled on a conflict between federal and state law regarding tobacco inspection standards. The State of Georgia had enacted its own regulations that were stricter than those established by Federal law under the Tobacco Inspection Act. A group of tobacco growers and warehousemen in Georgia challenged these state laws as being pre-empted by federal legislation which they claimed was intended to provide uniform national standards for tobacco grading and thus supersede any conflicting state laws. The Supreme Court agreed with this argument, ruling in favor of Hussey et al., stating that when Congress legislates an area it is assumed to be exclusive unless otherwise specified explicitly or implicitly within the statute itself. In this case, there was no such indication from Congress allowing concurrent regulation by states over federally regulated areas like tobacco inspection standards; hence Georgia's additional requirements were deemed invalid due to their inconsistency with Federal law.

In the dissenting opinion for Campbell, Commissioner of Agriculture of Georgia, et al. v. Hussey et al., Justice Frankfurter disagreed with the majority's decision that a federal law preempted a conflicting state law concerning tobacco inspection standards. He argued that Congress did not intend to occupy the entire field of tobacco regulation and therefore did not intend to exclude states from enacting their own regulations in this area. Furthermore, he contended that there was no actual conflict between the federal and state laws because they could be read harmoniously: while the federal law set minimum standards for tobacco quality, it allowed states to impose additional requirements if they so chose. Thus, according to Justice Frankfurter’s interpretation, both laws could coexist without undermining each other's objectives or disrupting interstate commerce.