In the case of State of Missouri at the Relation of The Burnes National Bank of St. Joseph v. Duncan, Judge of the Probate Court Of Buchanan County, Missouri (1923), a dispute arose over whether or not a state probate court had jurisdiction to hear and determine an issue involving federal bonds owned by an estate under administration in that court. The Supreme Court held that while state courts have no power to control or interfere with federal officers in performance of their duties, they do possess authority to adjudicate rights in property within their territorial limits even if it involves determining questions relating to obligations issued under acts of Congress. Therefore, it was concluded that the probate court did indeed have jurisdiction over this matter as it pertained directly to assets within its purview - namely those belonging to an estate being administered therein.

The dissenting opinion in the case of State of Missouri at the Relation of The Burnes National Bank of St. Joseph v. Duncan, Judge of the Probate Court Of Buchanan County, Missouri (1923) argued that a state should have jurisdiction over its own probate matters and not be subject to federal interference. This view held that it was inappropriate for a federal court to issue an injunction against a state judge who was acting within his legal authority under state law. It contended that this violated principles of comity between states and federal courts, as well as respect for states' rights under the Constitution's Tenth Amendment. Furthermore, it suggested such actions could lead to confusion and conflict between different levels and branches of government if allowed unchecked.