In the case of Mitchell v. United States et al., 1940, the U.S Supreme Court ruled that a federal court could not enjoin state officials from enforcing an unconstitutional state statute against individuals who were not parties to the suit. The plaintiff, Mitchell, was a member of Jehovah's Witnesses and sought an injunction to prevent enforcement of a Louisiana law requiring licensing for distributors of literature on public streets. He argued this violated his First Amendment rights. However, he had never applied for such license nor been prosecuted under it; thus he lacked standing to sue as there was no actual controversy involving him personally at stake in litigation. The Court held that while declaratory relief might be available if Mitchell were threatened with prosecution or suffered other injury due to enforcement efforts directed specifically at him, injunctive relief would only be appropriate where necessary to protect legal rights pending final adjudication - circumstances absent here.

In the dissenting opinion for Mitchell v. United States, Justice Roberts argued that the majority's decision to uphold a federal law prohibiting interstate transportation of women for immoral purposes was an overreach of Congress' power under the Commerce Clause. He contended that this case did not involve commerce in any ordinary sense and thus fell outside Congress' jurisdiction. Instead, he believed it should be left up to individual states to regulate morality within their borders as part of their police powers. Furthermore, he warned against using broad interpretations of constitutional provisions like the Commerce Clause as a means for expanding federal authority into areas traditionally reserved for state control.