In the case of Ex parte IN THE MATTER OF LINCOLN GAS & ELECTRIC LIGHT COMPANY, 1921, the Lincoln Gas & Electric Light Company filed a petition for writs of prohibition and mandamus against Judge Woodrough. The company sought to prevent him from proceeding with bankruptcy proceedings that had been initiated by certain creditors. The Supreme Court held that it did not have jurisdiction over this matter because there was no final judgment or decree made in any court which could be reviewed by them under Section 24b of the Judicial Code. Furthermore, they stated that even if they did have jurisdiction, they would still deny the application as it lacked merit since a judge has discretion on whether to approve or dismiss an involuntary bankruptcy petition after hearing evidence presented at a preliminary hearing.

In the dissenting opinion for Ex parte IN THE MATTER OF LINCOLN GAS & ELECTRIC LIGHT COMPANY, 1921, Justice Holmes argued that the Court should not have intervened in this case. He believed that it was inappropriate for the Supreme Court to step into a matter of state law and regulation unless there were clear constitutional issues at stake. In his view, Lincoln Gas & Electric Light Company had failed to demonstrate any such constitutional violation. Furthermore, he pointed out that even if there were potential federal questions involved in this case, they could be adequately addressed by lower courts without requiring intervention from the Supreme Court. Therefore, according to Justice Holmes' dissenting opinion, granting certiorari in this instance represented an overreach of judicial power and undermined principles of federalism.