In the case of Conner v. Simler, 1960, the United States Supreme Court addressed a dispute over whether an arbitration award should be confirmed in federal or state court. The petitioner and respondent were members of a partnership agreement that included an arbitration clause for disputes. When disagreements arose about accounting practices and profit distribution, they sought resolution through arbitration as per their contract's terms. The arbitrators ruled in favor of the petitioner (Conner), but when he attempted to confirm this decision at a federal district court under Section 9 of Federal Arbitration Act (FAA), his request was denied on grounds that it lacked jurisdiction because both parties were from same state - Indiana. The Supreme Court reversed this decision stating that FAA is not limited by diversity-of-citizenship requirements typically necessary for federal jurisdiction; rather it creates special statutory federal-question jurisdiction applicable to any suit seeking enforcement of contractual obligation to arbitrate regardless if all litigants are from same state or not. Therefore, even though there was no diversity between parties involved here, since matter related directly with enforcing provisions under FAA – which is 'Act of Congress' – it fell within ambit of ‘federal question’ giving district courts authority to adjudicate such cases.

In the dissenting opinion for Conner v. Simler, Justice Whittaker disagreed with the majority's interpretation of Section 301(a) of the Labor Management Relations Act. He argued that this section does not grant federal courts jurisdiction to enforce an arbitration award in a dispute between individual union members over their rights under a collective bargaining agreement. Instead, he believed it only grants jurisdiction to resolve disputes between employers and labor organizations or between labor organizations themselves. Furthermore, he contended that even if Section 301(a) did grant such jurisdiction, it would still be inappropriate for federal courts to intervene in this case because there was no evidence that either party had violated any provision of their collective bargaining agreement or refused to perform any obligation therein.