In the 1916 case of Horn v. Mitchell, the United States Supreme Court dealt with a dispute over property ownership and jurisdictional issues between federal and state courts. The plaintiff, Horn, had purchased land in Massachusetts that was previously owned by an individual who had declared bankruptcy. The defendant, Mitchell (a U.S Marshal), seized this property on behalf of the federal court handling the previous owner's bankruptcy proceedings. Horn sued for trespassing and argued that since he bought it from a state-appointed receiver before it was claimed by federal authorities, his claim to ownership should be recognized. The Supreme Court ruled against Horn stating that when there is conflict between state laws and those enacted under authority of Congress regarding bankruptcies; latter prevails as per Constitution’s Supremacy Clause which gives precedence to Federal law over State law in certain areas including Bankruptcy cases. This decision reaffirmed supremacy of Federal Law in matters where both State & Federal Courts have concurrent jurisdiction but conflicting interests.

In the dissenting opinion for Horn v. Mitchell, it was argued that the court had overstepped its jurisdiction by intervening in a matter of state law and procedure. The dissenting justices believed that Massachusetts courts were capable of handling their own legal matters without federal interference. They also disagreed with the majority's interpretation of due process rights under the Fourteenth Amendment, arguing that these rights did not extend to protecting an individual from being tried twice for the same crime in different jurisdictions (state and federal). Furthermore, they contended that there was no violation of double jeopardy as each sovereign government has its own laws and penalties; thus one could be prosecuted separately under both state and federal law for essentially similar crimes without infringing on constitutional protections against double jeopardy.