In the 1949 case District of Columbia v. Little, the U.S Supreme Court ruled in favor of the appellant, District of Columbia. The respondent, Little had been injured when he fell into a manhole while walking on a sidewalk in Washington D.C., and sued for damages claiming negligence on part of the city authorities. However, it was found that there were no signs or indications to suggest that city officials knew about this particular hazard prior to Mr. Little's accident; thus they could not be held liable for failing to correct an issue they were unaware existed. The court concluded that without proof showing actual or constructive notice given to municipal authorities regarding such defects or dangers within reasonable time before an accident occurs, municipalities cannot be held responsible under circumstances like these.

In the dissenting opinion for the case District of Columbia v. Little, 1949, it was argued that the majority's decision to uphold a fine imposed on a street vendor by local authorities in Washington D.C., despite his claim that he had been granted permission to sell goods by federal officials, represented an overreach of municipal authority and undermined federal supremacy. The dissenting justices contended that if a federal official gave explicit permission for an activity which is otherwise prohibited under local law, then this should supersede any conflicting municipal regulations or penalties. They further asserted that upholding such fines could potentially lead to situations where individuals are punished twice for the same act - once by local authorities and again by federal ones - thereby violating principles of double jeopardy. Ultimately, they believed this ruling set a dangerous precedent whereby municipalities could effectively nullify decisions made at the national level simply through their power to impose fines.