The case of Jackie Holder, et al. v. E.K. Hall Sr., et al., in 1993 revolved around a dispute over the ownership and control of two family corporations that owned significant real estate assets in Georgia. The plaintiffs, who were minority shareholders, alleged that the defendants (majority shareholders) had breached their fiduciary duties by misappropriating corporate assets for personal use and failing to pay dividends or provide financial information about the companies' operations. They sought an injunction to prevent further misuse of corporate funds as well as damages for past misconduct. However, the Supreme Court ruled against them on procedural grounds without addressing these substantive claims directly: it held that they should have brought their suit derivatively on behalf of the corporation rather than individually because any harm from such breaches would primarily affect the company itself rather than its individual members separately.

The dissenting opinion in the case of Jackie Holder, Etc., et al. v. E.K. Hall, Sr., et al., argued that the majority's decision to deny a writ of certiorari was incorrect and inconsistent with previous Supreme Court rulings on similar issues related to sovereign immunity under the Eleventh Amendment. The dissenters believed that this case presented an important question about whether or not state officials could be sued for damages in their individual capacities when they violate federal law while acting within their official roles as public servants. They contended that by refusing to hear this case, the court missed an opportunity to clarify its stance on this contentious issue and potentially rectify what they saw as a misinterpretation of precedent by lower courts.