In the case of Joan Growe, Secretary of State of Minnesota, et al. v. James Emison, et al., 1992, the Supreme Court ruled that federal courts should not intervene in state redistricting efforts when a valid plan is likely to be implemented by the state itself in a timely manner. The dispute arose after Minnesota's 1990 census results required it to lose one congressional seat and thus redraw its district lines. When no agreement could be reached on how this should be done within the stipulated time frame due to political disagreements between Democratic Governor Rudy Perpich and Republican-controlled legislature, plaintiffs sought relief from federal court which created its own redistricting plan for use in upcoming elections. However, during appeal process at Supreme Court level it was noted that despite delays Minnesota had subsequently managed to pass an acceptable redistricting law before next election cycle began - thereby rendering any need for federal intervention moot as per principles laid down under 'abstention doctrine'. Hence judgement was reversed with instructions for lower court to dismiss complaint.

In the dissenting opinion for Joan Growe, Secretary of State of Minnesota, et al. v. James Emison, et al., Justice Scalia argued that federal courts should not have intervened in a state's redistricting process until it was clear that the state would fail to produce a constitutional plan in time for the upcoming election. He believed this intervention violated principles of federalism and comity by unnecessarily interfering with states' rights to manage their own electoral affairs. Furthermore, he contended that there was no evidence suggesting Minnesota wouldn't be able to create an acceptable redistricting plan before elections took place; thus making federal court involvement premature and unwarranted.