The U.S. Supreme Court case Printz v. United States in 1996 revolved around the constitutionality of a provision in the Brady Handgun Violence Prevention Act that required local chief law enforcement officers (CLEOs) to perform background checks on prospective handgun purchasers within five business days of an attempted purchase. Jay Printz, Sheriff/Coroner for Ravalli County, Montana, along with other CLEOs from Arizona and Montana challenged this mandate arguing it violated the Tenth Amendment which reserves powers not delegated to the federal government by the Constitution for states or individual people. The court ruled 5-4 in favor of Printz stating that while Congress could encourage states to adopt certain regulations through financial incentives, it couldn't directly compel state officials to enforce federal laws as it would infringe upon state sovereignty underlined by Tenth Amendment principles.

In the dissenting opinion of Jay Printz, Sheriff/Coroner, Ravalli County, Montana v. United States (1996), Justice Stevens argued that the majority's decision was a departure from established constitutional principles and historical practices. He contended that there is no textual support in the Constitution for prohibiting Congress from directing state officers to implement federal laws. Furthermore, he pointed out that such commands have been issued throughout history without any question about their constitutionality until this case arose. The dissent also criticized the majority’s reliance on an interpretation of “dual sovereignty” which they believed was not supported by either text or precedent and could undermine cooperative federalism where national and local authorities work together to address common problems. Finally, Justice Stevens expressed concern over how this ruling might limit Congress' ability to address national issues effectively through local enforcement.