In the 1936 case Employers Reinsurance Corp. v. Bryant, U.S. District Judge, the United States Supreme Court dealt with a dispute over jurisdiction and venue in a suit between an insurance company and its policyholder. The plaintiff, Employers Reinsurance Corporation (ERC), sought to prevent enforcement of a state court judgment obtained by their policyholder against them for failure to pay on an insurance claim following a fire loss at his property in Missouri. ERC argued that they were not properly served notice of the lawsuit because it was sent to their office in Kansas City, Kansas instead of New York where they are incorporated and have their principal place of business. The Supreme Court ruled against ERC stating that service had been correctly made under Missouri law which allows for service on foreign corporations through any officer or agent found within the state; as such there was no violation of due process rights as claimed by ERC since they did receive actual notice about proceedings even if it wasn't delivered directly at their main office location.

In the dissenting opinion for Employers Reinsurance Corp. v. Bryant, it was argued that the majority's decision to allow federal courts to enjoin state court proceedings in certain circumstances undermined principles of comity and federalism. The dissent contended that such a broad interpretation of Section 265 of the Judicial Code (which generally prohibits federal courts from granting injunctions to stay proceedings in state courts) could lead to unnecessary interference with state judicial processes and potentially create conflicts between federal and state authorities. They also expressed concern about potential abuse or misuse of this power by litigants seeking an unfair advantage in their cases, which would undermine public confidence in both systems' integrity. Furthermore, they disagreed with the majority's view that there were exceptional circumstances justifying an exception here because they believed these issues should be resolved through normal appellate procedures rather than extraordinary remedies like injunctions.