In the 1904 case of Harris v. Balk, the U.S. Supreme Court ruled on a matter concerning personal jurisdiction and debt collection across state lines. The case involved two individuals: Benjamin Balk, a North Carolina resident who owed money to Ephraim Harris from Maryland; and Jacob Epstein from Baltimore who was owed money by Harris. When Balk visited Maryland, Epstein seized his property as collateral for what Harris owed him - despite having no legal claim over Balk's debts in that state. The court held that seizing someone’s property under these circumstances was constitutional because it fell within the purview of due process rights granted by the Fourteenth Amendment. It reasoned that since Balk had voluntarily entered into Maryland (thus subjecting himself to its laws), he could be considered temporarily "present" there through his seized property even after leaving. This decision expanded states' power to exercise jurisdiction over non-residents but also raised concerns about potential abuses of this authority when dealing with interstate financial obligations or disputes.

In the dissenting opinion for Harris v. Balk, Justice Harlan argued that the Supreme Court of North Carolina had no jurisdiction over a Maryland resident who was temporarily in North Carolina when he was served with process to appear as defendant in an attachment suit against another Maryland resident. He contended that such exercise of jurisdiction violated due process rights under the Fourteenth Amendment. Harlan believed that personal service within a state's borders did not automatically confer jurisdiction if it would violate principles of fair play and substantial justice. He also pointed out inconsistencies between this ruling and previous rulings by the same court on similar matters, arguing for more consistent application of legal principles regarding interstate jurisprudence.