In the 1980 case Federated Department Stores, Inc. v. Moitie, the U.S Supreme Court ruled that a federal court cannot refuse to hear a case on grounds of "wise judicial administration" if it has jurisdiction over the matter. The dispute began when Bernard Moitie and others filed an antitrust lawsuit against Federated Department Stores in California state court; however, they lost their claim due to lack of evidence proving conspiracy among defendants. They then attempted to refile their suit in federal court under different legal theories but were denied by both district and appellate courts citing res judicata (a matter already judged). Upon reaching the Supreme Court, justices held that lower courts had erred in refusing jurisdiction based on policy considerations rather than law itself - emphasizing that once jurisdiction is established, dismissal should only occur under codified exceptions or doctrines like res judicata or collateral estoppel.

In the dissenting opinion for Federated Department Stores, Inc. v. Moitie et al., Justice Brennan disagreed with the majority's interpretation of res judicata and its application to bar a second lawsuit after voluntary dismissal of an initial suit without prejudice. He argued that this approach was overly rigid and failed to consider important policy considerations such as fairness, efficiency, and judicial economy. The justice believed that plaintiffs should have the right to voluntarily dismiss their case without prejudice in order to correct procedural or substantive errors in their original complaint before refiling it again later on if necessary. In his view, barring them from doing so would unfairly penalize litigants who may not be familiar with complex legal procedures or who might make honest mistakes when filing lawsuits.