In the case of Rosado et al. v. Wyman, Commissioner of Social Services of New York, et al., 1969, a group of welfare recipients challenged changes made to the Aid to Families with Dependent Children (AFDC) program by New York State's Department of Social Services. The plaintiffs argued that these changes violated federal law because they reduced their benefits without considering individual needs and circumstances as required by federal standards for state participation in AFDC programs. The Supreme Court ruled in favor of the plaintiffs, stating that while states have considerable discretion in administering their welfare programs under broad federal guidelines, they must still comply with minimum federally mandated standards designed to ensure fair treatment for all recipients.

In the dissenting opinion for Rosado v. Wyman, Justice Harlan argued that the court overstepped its bounds by ruling on a case not yet ripe for review. He believed that it was premature to rule on New York's revised welfare program because it had not been fully implemented or reviewed by the Department of Health, Education and Welfare (HEW). Furthermore, he contended that this decision violated principles of federalism as it interfered with state sovereignty in determining their own welfare policies. In his view, if there were issues with New York’s plan after HEW approval and implementation, those affected could then seek judicial review based on specific grievances rather than hypothetical ones. Thus, he felt the majority acted prematurely and without proper respect for state autonomy in social policy matters.