The case of In re Commonwealth of Massachusetts, 1904, revolved around the issue of whether a state could sue on behalf of its citizens in federal court. The Supreme Court held that it could not. The Commonwealth had attempted to bring suit against Rhode Island and New York for alleged violations of interstate commerce laws which they claimed were causing harm to their citizens. However, the Court ruled that states cannot represent their citizens in this way because they are not "real parties" with an interest in such litigation. Instead, individual citizens must bring these suits themselves if they believe their rights have been violated.

The dissenting opinion in the case of In re Commonwealth of Massachusetts, 1904, argued that the Supreme Court did not have jurisdiction to hear this case. The dissenters believed that it was a matter for state courts and should be resolved at that level. They also disagreed with the majority's interpretation of federal law, arguing instead for a more limited view on federal power over states' rights. Furthermore, they expressed concern about potential implications for future cases if such broad interpretations were allowed to stand unchallenged. This perspective emphasized respect for state sovereignty and cautioned against an overly expansive reading of constitutional provisions related to interstate commerce and other areas where federal authority might override state laws or decisions.