The case of Forbes v. State Council of Virginia, Junior Order United American Mechanics of the State of Virginia in 1909 revolved around a dispute over the distribution and use of funds from an insurance policy. The plaintiff, Mr. Forbes, was a member of the defendant organization and had taken out an insurance policy through them which he later assigned to his wife as beneficiary. Upon his death, instead of paying out the full amount to Mrs. Forbes directly, the organization paid part to her and deposited another portion into its own treasury for future payments towards her - this being their standard practice for such cases based on their constitution and bylaws. Mrs. Forbes sued for recovery but lost at both trial court level and state supreme court level due to these rules within the organization's constitution that she was deemed aware off when accepting benefits from it. Upon appeal at U.S Supreme Court level however; it ruled in favor Mrs.Forbes stating that despite any internal rules or practices within organizations like these; they cannot supersede established laws regarding contracts (in this case life-insurance policies) where clear beneficiaries are named who should receive full amounts upon maturity without interference.

In the dissenting opinion for Forbes v. State Council of Virginia, Junior Order United American Mechanics of the State of Virginia, Justice Harlan argued that the majority's decision was a violation of constitutional rights and principles. He contended that by allowing an organization to exclude individuals based on their religious beliefs or nationality, it contradicted America's fundamental values and commitment to freedom and equality. Furthermore, he believed this ruling could set a dangerous precedent where organizations could discriminate against certain groups without legal repercussions. This would undermine civil liberties protected under the Constitution such as freedom from discrimination based on religion or national origin. In essence, Justice Harlan disagreed with the majority’s interpretation of private associations' right to self-governance in relation to individual rights protection.