In Pettibone v. Nichols (1906), the U.S. Supreme Court ruled in favor of George A. Pettibone, a labor leader who was charged with conspiracy to commit murder following the assassination of Idaho's former governor Frank Steunenberg. The court held that Idaho authorities had violated Pettibone's constitutional rights by kidnapping him from Colorado and forcibly transporting him to Idaho for trial without going through proper extradition procedures as required under Article IV, Section 2 of the Constitution and federal law governing interstate rendition. The decision reinforced states' obligations to respect individuals' due process rights when seeking their transfer from another state for criminal prosecution, emphasizing that no state can exercise its authority beyond its territorial limits or infringe upon another state’s sovereignty.

In the dissenting opinion for Pettibone v. Nichols, Justice Harlan argued that the majority's interpretation of federal law was too narrow and failed to adequately protect workers' rights. He contended that any conspiracy intended to obstruct interstate commerce should be considered a federal offense, regardless of whether it involved violence or not. In his view, this included labor strikes aimed at disrupting business operations. By limiting the scope of federal jurisdiction in such cases, he believed the court was undermining Congress's authority under the Commerce Clause and leaving workers vulnerable to exploitation by powerful corporations. Furthermore, he disagreed with the majority’s assertion that state courts were better suited to handle these matters as they might lack objectivity due their potential bias towards local interests.