In the Orloff v. Willoughby case of 1952, Dr. Arthur Orloff was drafted into the U.S Army during World War II and commissioned as a First Lieutenant in the Medical Corps due to his medical background. After serving for two years, he requested a discharge but it was denied by Colonel Willoughby who instead ordered him to active duty as an enlisted man rather than an officer. Orloff sued on grounds that this action violated laws governing military commissions and promotions. The Supreme Court ruled against Orloff stating that once someone voluntarily joins or is lawfully conscripted into the armed forces, they must abide by its rules and regulations including assignments given by superior officers regardless of their professional qualifications or rank held previously. The court further stated that such decisions are best left to those with expertise in military matters rather than civilian courts.

In the dissenting opinion for Orloff v. Willoughby, Justice William O. Douglas argued that Dr. Orloff's commission as a First Lieutenant in the Army Medical Corps did not give military authorities the right to assign him duties outside of his professional capacity as a doctor without his consent. He contended that since Dr. Orloff was commissioned under an Act of Congress which specifically provided for the appointment of medical professionals into the armed forces, he should only be assigned tasks related to this field unless he voluntarily accepted other assignments or there were exceptional circumstances such as war or national emergency present at that time.