In the 1909 case of McClellan v. Carland, the United States Supreme Court addressed a jurisdictional dispute between federal and state courts. The plaintiff, McClellan, had filed for an injunction in a South Dakota state court to prevent foreclosure on his property by creditors who were pursuing their claim in federal court. While this was pending, he also sought relief from the federal judge overseeing his bankruptcy proceedings but was denied due to lack of jurisdiction because of the ongoing state proceeding. On appeal to the U.S. Supreme Court, it held that when two courts have concurrent jurisdiction over a matter - as here with both bankruptcy and equity claims - whichever court first gains possession or control over property at issue maintains exclusive jurisdiction until it has fully disposed of all matters before it regarding said property; other courts must defer action until then even if they would otherwise have authority under different circumstances (the "first-to-file" rule). Therefore, since McClellan's creditors initiated their claim in federal court prior to him seeking relief from state court which led to its obtaining control over his assets first through receivership order issued therein earlier than any orders made by latter one about same subject-matter i.e., those properties involved herein), only that former tribunal could decide issues related thereto including whether or not grant requested injunction against foreclosures thereon.

In the dissenting opinion for McClellan v. Carland, Justice Harlan argued that the majority's decision to uphold a federal court's jurisdiction over state cases was an infringement on states' rights. He believed that this ruling would allow federal courts to interfere in matters traditionally handled by state courts and could potentially disrupt the balance of power between federal and state governments. Furthermore, he expressed concern about how this decision might impact future cases involving similar issues of jurisdictional authority. In his view, allowing a lower federal court to stay proceedings in a case already pending before it when another suit is subsequently brought in a different forum (state or otherwise) undermines principles of judicial efficiency and comity among jurisdictions.