In the case of Levinson et al. v. Deupree, Ancillary Administrator in 1952, the U.S Supreme Court was asked to determine whether a federal court could exercise jurisdiction over an ancillary administration proceeding initiated by non-resident creditors against a decedent's estate located in another state. The plaintiffs were creditors from New York who sought to recover debts owed by an Alabama resident who had died intestate (without leaving a will). They filed their claim with an Alabama probate court but were denied relief on grounds that they failed to comply with certain procedural requirements under Alabama law for out-of-state creditors. The Supreme Court held that federal courts do not have jurisdiction over such matters because they are essentially local and pertain exclusively to the laws of individual states concerning property rights and inheritance issues within their borders. It further noted that while Congress has broad powers under Article III of the Constitution to define and limit the jurisdiction of lower federal courts, it cannot extend this authority into areas reserved for state control without violating principles of federalism enshrined in our constitutional system.

In the dissenting opinion for Levinson et al. v. Deupree, Ancillary Administrator, Justice Robert H. Jackson disagreed with the majority's decision to uphold a lower court ruling that denied recovery of assets from an estate based on a claim of unjust enrichment. He argued that this case was not about whether or not there had been fraud or misrepresentation but rather if one party had received benefits without providing fair compensation in return - which he believed they did. Justice Jackson also criticized the majority for ignoring established legal principles and creating new law instead of applying existing ones correctly. He contended that their interpretation could lead to unfair results in future cases by allowing parties who have benefited unfairly at another's expense to avoid paying what they owe simply because no fraudulent intent can be proven.