In the 1916 case of Chaloner v. Sherman, John Armstrong Chaloner contested his confinement in a mental institution by his family members who controlled his estate. The Supreme Court ruled that it did not have jurisdiction over this matter because it was essentially a dispute about property rights and inheritance rather than civil liberties or constitutional law. The court held that state courts had already determined Mr. Chaloner's mental competency and thus he could not challenge their findings at the federal level under habeas corpus proceedings (a legal action through which detainees can seek relief from unlawful imprisonment). This decision underscored the principle of "res judicata," meaning an issue that has been previously judged cannot be re-litigated.

In the dissenting opinion for Chaloner v. Sherman, it was argued that the court should not have upheld a Virginia law allowing involuntary commitment to mental institutions without a jury trial. The justice believed this violated an individual's constitutional right to due process under the Fourteenth Amendment. He contended that such decisions should be made by juries rather than doctors because of potential bias in medical opinions and because of the serious nature of depriving someone of their liberty based on mental health status. Furthermore, he expressed concern about states having different standards for commitment and how this could lead to abuses or inconsistencies in treatment across state lines.