In the case of Dunbar v. Dunbar, 1902, the U.S Supreme Court was tasked with determining whether a wife's right to alimony from her husband could be enforced in another state. The couple had divorced in Mississippi and the court there granted Mrs. Dunbar alimony payments which Mr. Dunbar failed to pay after moving to Louisiana. Mrs. Dunbarr then filed suit in Louisiana for enforcement of these payments. The Supreme Court ruled that while states are not required by full faith and credit clause of Constitution or otherwise to enforce penal laws of other states, they may do so if they choose; however, an obligation imposed on a husband by decree awarding permanent alimony is not penal within this rule but is rather an obligation based on marriage contract recognized everywhere as justly binding upon him. Therefore it concluded that Louisiana courts were obliged under Full Faith and Credit Clause (Article IV Section 1) of US Constitution to recognize and enforce Mississippi’s judgment ordering Mr.Dunbar to pay his ex-wife alimony.

In the dissenting opinion for Dunbar v. Dunbar, Justice Harlan argued that the majority's decision to deny Mrs. Dunbar alimony was a misinterpretation of Louisiana law and an infringement on her rights as a wife. He contended that under Louisiana law, marriage is considered more than just a civil contract; it also has social implications which should be taken into account when deciding matters such as alimony payments. According to him, by denying Mrs. Dunbar financial support from her husband after their divorce, the court failed to recognize these broader societal aspects of marriage and thus violated her rights under state law.