In the case of Goldstein et al. v. California, the U.S Supreme Court ruled that states have the authority to enforce copyright laws for sound recordings made within their borders prior to February 15, 1972. The court held that Congress did not intend federal law to pre-empt state protection when it passed a statute in 1971 granting federal copyright protection only to recordings fixed after February 15, 1972. This decision arose from an appeal by record pirates who were convicted under California's record piracy statute and argued that this state law was superseded by federal legislation on copyrights. However, the Supreme Court disagreed with this argument and upheld their convictions.

The dissenting opinion in the case of Goldstein et al. v. California argued that Congress, not states, should have exclusive jurisdiction over copyright laws due to the Commerce Clause and Copyright Clause in the Constitution. The justices believed that allowing individual states to enact their own copyright laws could lead to a patchwork system with varying protections across state lines, potentially disrupting interstate commerce and creating confusion among creators about their rights. They also pointed out that sound recordings were not explicitly excluded from federal copyright protection at the time; therefore, they felt it was inappropriate for California to step into an area where federal law had already been established but simply hadn't yet been applied specifically to this medium.