In the case of Campbell v. Wadsworth et al., 1918, the U.S Supreme Court was tasked with determining whether a federal court had jurisdiction over a dispute involving land in Arizona that was part of an Indian reservation. The plaintiff, Campbell, claimed ownership based on a patent issued by the United States while defendants Wadsworth and others asserted rights through leases from individual Indians who were allotted parcels under an Act of Congress. The lower courts ruled in favor of Campbell but upon appeal to the Supreme Court, it reversed these decisions stating that federal courts did not have jurisdiction as there was no diversity between parties (all being citizens) nor any question arising under Constitution or laws of United States; rather it involved interpretation and application of Indian right-of-way act which is within exclusive purview of state courts.

In the dissenting opinion for Campbell v. Wadsworth, it was argued that the majority's decision to uphold a state law requiring compulsory vaccination during an epidemic violated individual rights and liberties. The dissenting justices believed that such laws should only be enacted when there is clear evidence of imminent danger to public health, which they did not believe was present in this case. They also expressed concern about potential abuses of power by public health officials and warned against allowing fear of disease to override constitutional protections for personal liberty. Furthermore, they questioned whether mandatory vaccination could actually achieve its intended goal of preventing disease spread given uncertainties about vaccine efficacy and risks associated with vaccine side effects.