In the Gulf Oil Corp. v. Gilbert case of 1946, the U.S Supreme Court ruled in favor of Gulf Oil Corporation, establishing a precedent for forum non conveniens - a discretionary power that allows courts to dismiss a case where another court or forum is much better suited to hear the case. The plaintiff, Gilbert Storage & Transfer Co., had filed suit against Gulf Oil in Virginia despite both companies being based in Alabama and all relevant events occurring there as well. The defendant argued that it was inconvenient and unfair to have the trial held so far from its home base when no significant connection existed between their dispute and Virginia jurisdiction. The Supreme Court agreed with this argument stating that while plaintiffs generally have discretion over where they file suits, this privilege should not be used oppressively or vexatiously against defendants by choosing an inconvenient location without any substantial justification.

In the dissenting opinion for Gulf Oil Corp. v. Gilbert, Justice Murphy argued that the majority's decision to dismiss a case based on forum non conveniens (the legal principle allowing courts to refuse jurisdiction when another court is more appropriate) was an abuse of discretion and violated principles of federalism. He contended that it was not within the Court’s power to decide where a plaintiff should bring their suit, especially if they have chosen a legally valid venue. Furthermore, he expressed concern about potential prejudice against plaintiffs due to this ruling as it could limit their ability to choose venues favorable for them or force them into less convenient forums which might hinder effective litigation. He also pointed out that there were no exceptional circumstances in this case warranting dismissal under forum non conveniens doctrine; hence, dismissing it would set an unfavorable precedent.