In the case of Key et al. v. Doyle et al., 1977, the United States Supreme Court addressed whether a state could require non-resident attorneys to associate with local counsel in order to practice law within its jurisdiction. The plaintiffs were out-of-state lawyers who wanted to represent clients in Georgia without having to work with an in-state attorney, as required by Georgia's rules for practicing law there. They argued that this rule violated their rights under the Privileges and Immunities Clause of Article IV and the Commerce Clause of the U.S Constitution. The court ruled against them, upholding Georgia's requirement for non-resident attorneys to associate with local counsel before they can practice law within its borders. It found no violation of either clause because states have significant interest in regulating legal practices within their jurisdictions and ensuring that all practitioners are competent and accountable.

In the dissenting opinion for Key et al. v. Doyle et al., Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's decision to uphold Georgia's statute requiring a unanimous jury verdict in civil cases was inconsistent with previous Supreme Court rulings on the Sixth Amendment right to trial by jury. The dissenters believed that this requirement violated defendants' constitutional rights because it allowed a single juror to effectively veto a verdict supported by all other jurors, thereby undermining the collective judgment of the jury as a whole. They also pointed out that there is no historical basis for requiring unanimity in civil trials and criticized their colleagues for failing to provide any compelling reason why such an unusual rule should be upheld.