In the case of Gaff, Executrix v. Gottfried, the Supreme Court of the United States was asked to decide whether a state court had the authority to order a defendant to pay a judgment in a case where the defendant had not been served with process. The case arose when the plaintiff, Gaff, brought a suit against Gottfried in a state court in Pennsylvania. Gaff alleged that Gottfried had failed to pay a debt that he owed to Gaff. Gaff obtained a judgment against Gottfried, but Gottfried had not been served with process. The Supreme Court held that the state court did not have the authority to order Gottfried to pay the judgment. The Court reasoned that due process requires that a defendant be served with process before a court can enter a judgment against him. The Court noted that the state court had not served Gottfried with process, and thus the judgment was void. The Court also noted that the state court had not provided Gottfried with an opportunity to be heard, which is also required by due process. The Court concluded that the state court did not have the authority to enter a judgment against Gottfried without providing him with due process. The Court reversed the judgment of the state court and remanded the case for further proceedings.

In the dissenting opinion of Gaff, Executrix v. Gottfried, Justice Black argued that the majority's decision was in conflict with prior Supreme Court precedent and could lead to a dangerous expansion of federal power over state law. He noted that while Congress has broad authority to regulate interstate commerce under the Commerce Clause, it does not have unlimited power and must respect certain limits imposed by state laws. In this case, he believed that the majority had gone too far in allowing Congress to override a validly enacted state statute without any clear indication from Congress itself as to its intent or purpose for doing so. Furthermore, he argued that such an expansive interpretation of congressional authority would undermine states' ability to protect their citizens through legislation tailored specifically for their own needs and interests.