In the 1901 case Compagnie Francaise de Navigation a Vapeur v. Louisiana State Board of Health, the U.S. Supreme Court ruled in favor of the Louisiana State Board of Health. The French company had challenged a state law that gave authority to the board to exclude or detain any vessel arriving at New Orleans from foreign ports during times when there was perceived risk of infectious disease. The court held that this power did not infrally upon federal jurisdiction over immigration and commerce with foreign nations, as it was within states' police powers to protect public health and safety. This decision affirmed states' rights in matters concerning public health, even if they intersected with areas typically under federal control.

In the dissenting opinion for COMPAGNIE FRANCAISE DE NAVIGATION A VAPEUR v. LOUISIANA STATE BOARD OF HEALTH, Justice Harlan disagreed with the majority's interpretation of state and federal powers. He argued that Louisiana's law allowing a state board to exclude healthy persons from entering the state was unconstitutional as it violated individual rights protected by the Fourteenth Amendment. Furthermore, he contended that this power belonged exclusively to Congress under its authority to regulate interstate commerce and immigration into the United States. In his view, if each State had such broad public health powers as claimed by Louisiana, then they could effectively control national foreign policy or disrupt national trade policies - areas clearly within federal jurisdiction.