In the case of Ohio ex rel. Eaton v. Price, Chief of Police in 1958, the Supreme Court ruled on a matter concerning civil rights and police powers. The appellant was arrested for refusing to leave a privately owned restaurant after being asked by its owner due to his race. He filed suit against the chief of police claiming that his arrest violated his Fourteenth Amendment right to equal protection under law as he was discriminated based on race which led him to be denied service at a public establishment. The court held that while private discrimination may not be prohibited by the Constitution, state enforcement of such discrimination would violate an individual's constitutional rights. Therefore, if it were proven that Ohio’s criminal trespass law had been applied in this racially discriminatory manner then it would indeed infracate upon Eaton's Fourteenth Amendment rights. However, since there wasn't enough evidence presented showing racial bias in application or enforcement of Ohio’s criminal trespass law during trial proceedings; hence no violation could be established conclusively and thus appeal dismissed.

In the dissenting opinion for Ohio ex rel. Eaton v. Price, Chief of Police, 1958, Justice Harlan argued that the majority's decision to overturn a state court ruling on constitutional grounds was inappropriate and premature. He contended that there were unresolved factual issues in the case which should have been addressed by lower courts before reaching the Supreme Court level. Furthermore, he believed that it was not within this Court’s jurisdiction to decide whether or not an individual had exhausted all available remedies under state law before seeking federal relief; such matters should be left up to each respective state's judicial system. In his view, this approach would respect states' rights and maintain a proper balance between federal and state authority in legal proceedings.