In the case of Phillips Petroleum Co. et al. v. Jenkins, the U.S Supreme Court was tasked with deciding on a dispute involving oil and gas leases in Oklahoma. The plaintiffs, Phillips Petroleum Company and others, had obtained oil and gas leases from landowners who were allotted lands by Congress under an Act that restricted alienation or leasing of such lands for more than five years without approval from the Secretary of Interior - which they did not have at this time. When defendants drilled wells on these lands after their lease expired but within five years period covered by plaintiff's unapproved lease, plaintiffs sued claiming exclusive rights to drill during that period based on their earlier unapproved lease agreement. The court ruled against Phillips Petroleum Company stating that since their original leases were made without obtaining necessary federal approval as required by law; hence they are invalid ab initio (from inception). Therefore, it does not provide any basis for claim against subsequent lessees who operated within legal bounds even if it is within the disputed five-year term.

In the dissenting opinion for Phillips Petroleum Co. et al. v. Jenkins, Justice Stone argued that the majority's decision to allow a state court to exercise jurisdiction over an out-of-state corporation was inconsistent with due process principles and previous Supreme Court rulings on personal jurisdiction. He contended that merely engaging in interstate commerce should not subject a company to lawsuits in any state where its products end up, especially when it has no control over their distribution after they leave its possession. Furthermore, he expressed concern about the potential burden on businesses if they had to defend themselves against litigation in every state where their goods are sold or used by third parties without their knowledge or consent.