In the 1932 case Palmer v. Bender, the United States Supreme Court ruled in favor of Bender, an administratrix. The dispute centered around a deceased individual's estate and whether it should be distributed according to Washington state law or Alaska territorial law. The decedent was a resident of Washington but had acquired significant property in Alaska during his lifetime through mining operations. According to Alaskan laws at that time, if there were no direct heirs (children or spouse), siblings could inherit; however, under Washington law, half would go to the parents and half to siblings. As such, different parties stood to benefit depending on which jurisdiction’s laws applied. The court decided that since most of the property was located in Alaska and obtained from activities within its territory while he resided there for extended periods each year - despite maintaining legal residence elsewhere - Alaskan inheritance laws should apply over those of his home state.

In the dissenting opinion for Palmer v. Bender, 1932, it was argued that the majority's decision to uphold a state law prohibiting non-residents from hunting migratory birds violated federal statutes and treaties designed to protect these species. The dissenting justices contended that such laws were unconstitutional as they interfered with Congress' power to regulate interstate commerce and contravened international agreements aimed at preserving bird populations. They further asserted that states did not have the authority to enact legislation which conflicted with federal law or treaty obligations. Therefore, in their view, the court should have struck down the state statute as invalid under Supremacy Clause of Constitution.