The U.S. Supreme Court case Roudebush v. Hartke et al., 1971, revolved around the contested election for a United States Senate seat in Indiana between Richard Lugar and Vance Hartke. After losing by a narrow margin, Lugar requested a recount under Indiana law but was denied by the lower courts on grounds that it would violate Article I of the Constitution which grants Congress power to judge elections' qualifications and returns of its members. The Supreme Court reversed this decision, ruling that recounts are an integral part of state election processes and do not infringe upon Congressional powers as they merely ascertain voters’ choice rather than determine who is qualified to serve in Congress or whether elected officials were properly chosen according to state laws.

In the dissenting opinion for Roudebush v. Hartke, Justice William O. Douglas argued that the majority's decision to allow a recount in an Indiana Senate race undermined the state's authority and violated principles of federalism. He contended that states have traditionally been given wide latitude in conducting their own elections, including determining how recounts should be handled. By stepping into this dispute and ordering a recount, he believed that the Supreme Court was overstepping its bounds and interfering with Indiana’s sovereignty rights to manage its internal affairs without undue interference from federal authorities or courts.