In the case of In re Converse, Petitioner (1890), the U.S. Supreme Court was asked to consider whether a federal court could issue an injunction against a state court proceeding in order to protect or effectuate its judgments. The petitioner, Mr. Converse, had previously obtained a judgment in his favor from a federal circuit court and sought to prevent further litigation on the same matter in state courts through an injunction issued by that same federal circuit court. However, the Supreme Court ruled against him stating that while it is within the power of lower federal courts to issue such writs as necessary for their effective functioning and protection of their jurisdiction; they cannot use this authority as means for direct interference with proceedings initiated independently under state laws before competent tribunals thereof unless there are exceptional circumstances which were not present here.

The dissenting opinion in the case of In re Converse, Petitioner (1890) argued that the majority's decision to deny habeas corpus relief was incorrect. The dissent believed that Mr. Converse had been unlawfully detained and his constitutional rights violated by being held without a proper warrant or hearing. They contended that due process had not been followed as he was denied an opportunity to challenge his detention before a neutral magistrate, which they saw as fundamental to American justice system principles. Furthermore, they disagreed with the majority's interpretation of extradition laws and felt it did not align with their intended purpose - protecting individuals from unlawful detentions across state lines rather than facilitating them.