In the case of New York v. O'Neill (1958), the U.S Supreme Court ruled on an extradition matter involving a man named Edward J. O’Neill, who was wanted in New York for grand larceny but had fled to Florida. The Governor of Florida refused to extradite him back to New York because he believed that O’Neill would not receive a fair trial due to prejudicial pretrial publicity in the press and public sentiment against him. The Supreme Court held that it is not within the power of a governor or any other authority except courts with jurisdiction over criminal matters, such as federal district courts or state supreme courts, to determine whether someone will get a fair trial in another state. It further stated that if there are concerns about potential prejudice impacting one's right to a fair trial, those issues should be addressed by filing motions before court proceedings begin rather than refusing extradition altogether. This decision reinforced principles related both interstate cooperation under Article IV’s Extradition Clause and constitutional rights under Sixth Amendment guaranteeing every defendant's right for impartial jury trials.

In the dissenting opinion for New York v. O'Neill, Justice Frankfurter disagreed with the majority's ruling that a state can compel an out-of-state witness to attend criminal proceedings within its jurisdiction. He argued that this decision violated principles of federalism and comity among states by allowing one state to impose its laws on another without consent or reciprocity. Furthermore, he contended that it was inappropriate for the Court to interpret Congressional silence on this issue as approval when Congress had not explicitly authorized such actions in legislation. Lastly, he expressed concern about potential abuses of power and violations of individual rights if states were allowed unchecked authority over non-residents in their criminal justice systems.