In the 1905 case of Joy v. City of St. Louis, the United States Supreme Court ruled in favor of the city, upholding its right to use eminent domain for urban redevelopment projects that were deemed beneficial to public welfare. The plaintiff, Mrs. Joy, owned a piece of land which was taken by the city under their power of eminent domain as part of an effort to improve and beautify certain areas within its boundaries. She argued that this action violated her Fourteenth Amendment rights because it did not serve a "public use". However, the court disagreed with her argument stating that cities have broad discretion when determining what constitutes public benefit or welfare and can therefore seize private property if they believe it will contribute towards these goals.

In the dissenting opinion for Joy v. City of St. Louis, Justice Harlan argued that the majority's decision was a departure from established principles of constitutional law and an intrusion on state sovereignty. He contended that Missouri had every right to change its constitution without interference from federal courts unless it violated rights protected by the U.S Constitution itself. The justice believed that there was no violation in this case as Missouri’s actions were within their sovereign power and did not infringe upon any federally protected rights or interests of the plaintiff, Mr.Joy. Furthermore, he asserted that if states could be restrained by federal courts from altering their own constitutions based on potential harm to private contracts or corporations, then state sovereignty would effectively cease to exist – a situation he deemed unacceptable under American Federalism.