The U.S. Supreme Court case Chicago, Rock Island & Pacific Railway Company v. Schendel in 1925 revolved around the issue of whether a state court had jurisdiction over an interstate commerce company for actions that occurred outside of the state's boundaries. The plaintiff, Schendel, was an administrator seeking damages from the railway company for wrongful death and personal injuries sustained by his decedent while working as a brakeman on one of their trains in Iowa - even though both parties were residents of Minnesota where the lawsuit was filed. The defendant argued that Minnesota courts lacked jurisdiction because all relevant events took place in Iowa. However, the Supreme Court ruled against this argument stating that since corporations are considered "persons" under law and can have multiple residences (wherever they do business), it is possible to sue them within any state where they operate if minimum contacts exist between them and said state - regardless if incidents happened elsewhere or not. Therefore, it upheld Minnesota’s right to exercise its judicial power over cases involving out-of-state occurrences concerning companies operating within its borders.

In the dissenting opinion for Chicago, Rock Island & Pacific Railway Company v. Schendel, Justice Holmes disagreed with the majority's interpretation of federal law and its application to state courts. He argued that a federal statute should not be used to interfere with or change established procedures in state courts unless it explicitly states such intent. In this case, he believed there was no clear indication from Congress that they intended for their legislation to alter how state courts handle cases involving interstate commerce disputes. Furthermore, he pointed out inconsistencies in previous rulings by the Court on similar matters which further complicated interpretations of congressional intent. Ultimately, Holmes felt that without explicit direction from Congress regarding changes to existing legal processes within individual states' jurisdictional boundaries, any assumption made by the Court would be an overreach of their authority.