In Church v. Hubbart, the Supreme Court of the United States held that a state court had jurisdiction to issue an injunction against a defendant who was attempting to remove property from another state in violation of its laws. The case arose when Reverend Samuel Church sought relief from John Hubbart, who had taken possession of certain goods belonging to Church and transported them out-of-state without his consent or knowledge. The Supreme Court found that although the removal occurred outside of New York State's borders, it still constituted an act done within New York for purposes of determining jurisdiction under Article III Section 2 Clause 1 (the "diversity clause") because it affected rights secured by New York law. As such, the Supreme Court affirmed the decision below granting injunctive relief against Hubbart and holding that he must return all items removed from New York State back into its boundaries.

In Church v. Hubbart, Chief Justice John Marshall wrote a dissenting opinion in which he argued that the Court should not have granted an injunction to prevent the defendant from entering onto land owned by the plaintiff. He reasoned that since there was no evidence of actual damage or injury caused by the defendant's entry, it would be inappropriate for a court to issue such an order without proof of harm. Furthermore, Marshall noted that injunctions are extraordinary remedies and should only be used when necessary; in this case, he believed granting one was unnecessary because other legal remedies were available to address any potential damages suffered by the plaintiff due to trespass on their property. In conclusion, Marshall asserted that while courts may grant injunctions if they deem them appropriate under certain circumstances, this particular situation did not warrant such action as there had been no showing of actual harm or injury resulting from the defendant's actions.