In the case of Collins et al. v. Hardyman et al., 1950, the United States Supreme Court ruled that private individuals cannot sue for damages under federal law unless they can demonstrate direct harm caused by a conspiracy to violate their constitutional rights. The plaintiffs in this case were members of a labor union who claimed that other members conspired to deprive them of their First Amendment rights through threats and intimidation tactics intended to suppress their freedom of speech and assembly. However, the court found no evidence that state officials or authorities had been involved in or supported these alleged conspiracies, which was necessary for such claims under Section 1985(3) of Title 42 (the Ku Klux Klan Act). Therefore, it concluded that only those directly harmed by actions involving state action could seek relief under federal law.

In the dissenting opinion for Collins et al. v. Hardyman et al., Justice Black argued that the majority's decision to dismiss the case was a misinterpretation of Section 1985(3) of Title 42, which provides civil remedies for conspiracy to deprive any person or class of persons equal protection under law. He contended that this statute should be interpreted broadly and not limited only to instances where state action is involved, as suggested by the majority ruling. According to him, private conspiracies aimed at infringing upon constitutional rights are just as harmful and thus should also fall within its purview. Furthermore, he criticized the court's refusal to hear evidence on whether such a conspiracy existed in this case before dismissing it outright based on jurisdictional grounds alone.