The Collins v. Miller case in 1919 revolved around the issue of whether a federal court had jurisdiction over an action brought by a citizen of one state against another state's officer to recover property seized under color of office, without diversity of citizenship or any federal question involved. The Supreme Court held that the lower courts did not have jurisdiction over such cases as it was purely based on local (state) law and there were no grounds for invoking federal jurisdiction. The plaintiff, Collins, argued that his constitutional rights were violated when Miller, a U.S Marshal from Louisiana, confiscated his property during prohibition enforcement activities. However, the court ruled that since both parties resided in Louisiana and there was no violation of any federally protected right - only potential violations under state law - this dispute should be resolved at the state level rather than involving federal courts.

In the dissenting opinion for Collins v. Miller, Justice Holmes argued that the majority's decision to uphold a federal law prohibiting interstate transportation of women for immoral purposes was an overreach of Congress' power under the Commerce Clause. He contended that while it is within Congress' authority to regulate commerce among states, this should not extend to moral issues or personal conduct unless they directly affect trade and business transactions between states. In his view, such matters are better left to individual state legislatures rather than being federally regulated. Furthermore, he expressed concern about potential misuse of this broad interpretation in future cases which could lead to unwarranted intrusion into people’s private lives by federal authorities.