In the 1907 U.S. Supreme Court case Ex parte Young, Edward S. Young, Attorney General of Minnesota was sued by stockholders of a railroad company for enforcing a state law that they believed violated their Fourteenth Amendment rights. The law in question reduced railway rates and imposed penalties on companies not complying with it. The plaintiffs argued this would bankrupt the company and deprive them of property without due process of law. They sought an injunction to prevent Young from enforcing the statute. The court ruled in favor of the plaintiffs, establishing what is known as "the doctrine of Ex parte Young," which allows federal courts to enjoin state officials from violating federal laws or constitutionally protected rights under certain circumstances despite sovereign immunity doctrines that typically protect states from such suits. This decision significantly expanded federal power over states' actions and has been instrumental in civil rights litigation since then because it provides individuals with a means to challenge unconstitutional state action in federal court.

In the dissenting opinion for Ex Parte Young, Justice Harlan disagreed with the majority's view that a federal court could enjoin a state official from enforcing an unconstitutional state statute. He argued that this decision violated principles of federalism and states' rights by allowing federal courts to interfere in matters within the purview of individual states. According to him, such interference was only justifiable if it was necessary to protect or enforce constitutionally guaranteed rights. Furthermore, he contended that there were other remedies available at both state and national levels for individuals who believed their constitutional rights had been infringed upon by a state law or action. Thus, he saw no need for expanding the jurisdiction of federal courts in this manner.