In the 1902 case Easton v. Iowa, the U.S. Supreme Court ruled that a state law prohibiting private banking without specific authorization did not violate the Fourteenth Amendment's Due Process Clause. The plaintiff, Mr. Easton, was convicted under an Iowa statute for operating a bank without proper authority and appealed on grounds that his conviction violated his constitutional rights to due process and equal protection of laws as guaranteed by the Fourteenth Amendment. However, in its decision authored by Justice John Marshall Harlan II, the court upheld Easton's conviction stating that states have broad powers to regulate businesses within their borders including banking activities if they deem it necessary for public welfare or safety reasons.

In the dissenting opinion for Easton v. Iowa, Justice Harlan argued that the majority's decision was a misinterpretation of the Fourth Amendment. He contended that it should not be applied to state actions and believed that this interpretation would lead to an overreach of federal power into state matters. Furthermore, he asserted that if every violation of personal rights by states were subject to review by federal courts, there would be no end to their interference in local affairs. In his view, such a broad application could potentially undermine states' ability to maintain order and enforce laws within their jurisdictions effectively.