The case of Northeast Bancorp, Inc. v. Board of Governors of the Federal Reserve System in 1984 revolved around a dispute over regional banking laws in Massachusetts and Connecticut that allowed out-of-state bank holding companies to acquire banks within these states only if their home state had reciprocal provisions for Massachusetts and Connecticut-based banks. The petitioners, two bank holding companies from New York and Maine, challenged these laws as violating the Commerce Clause by discriminating against interstate commerce. However, the Supreme Court upheld the lower court's decision favoring the Federal Reserve Board’s approval of acquisitions under such statutes on grounds that they were not protectionist but rather aimed at promoting local control over credit resources while allowing some degree of interstate banking expansion.

In the dissenting opinion for Northeast Bancorp, Inc. v. Board of Governors of the Federal Reserve System et al., Justice White disagreed with the majority's interpretation that federal law preempts state laws allowing interstate banking in certain circumstances. He argued that Congress had not explicitly stated an intention to preempt such state laws and therefore, they should be allowed to stand under principles of federalism. Furthermore, he contended that there was no conflict between these state laws and any existing federal statutes or regulations governing banking practices across states lines; thus, it was inappropriate for the Court to infer a Congressional intent to preempt where none existed expressly in statute or implicitly through conflicts with other legislation.