The U.S. Supreme Court case General Investment Company v. Lake Shore & Michigan Southern Railway Company et al., 1922, revolved around the issue of whether a federal court could enjoin state court proceedings in order to protect or effectuate its judgments. The plaintiff, General Investment Company, had previously obtained a judgment against the railway company in federal court and sought an injunction to prevent the railway from litigating similar issues in state courts. However, the Supreme Court held that while federal courts have authority under certain circumstances to restrain parties from proceeding with suits in state courts which would defeat or impair their jurisdiction or interfere with their judgments; they do not possess such power merely for protection or enforcement of their judgments when there is no interference with those judgments nor any attempt to thwart them by subsequent litigation elsewhere.

In the dissenting opinion for General Investment Company v. Lake Shore & Michigan Southern Railway Company, Justice McReynolds expressed his disagreement with the majority's decision to uphold a lower court ruling that allowed an injunction against shareholders from filing suits in state courts. He argued that this was a violation of their rights and an overreach of federal authority. According to him, there should be no interference by federal courts in cases where state courts have jurisdiction unless it is absolutely necessary to prevent irreparable damage or loss. Furthermore, he contended that such intervention could lead to confusion and conflict between different jurisdictions which would undermine public confidence in the judicial system as well as disrupt its smooth functioning.