In the case of Neely v. Martin K. Eby Construction Co., Inc., the U.S Supreme Court ruled that a federal court cannot review state court decisions in civil suits unless it is shown that there was an infringement on constitutional rights or federal law by the state courts. The case involved a dispute between Neely, who had been injured at work and his employer, Martin K. Eby Construction Co., over workers' compensation benefits under Arkansas law. After losing his claim in state courts, Neely sought to have his case reviewed by a federal district court which dismissed it for lack of jurisdiction but was later reversed by an appellate court stating that diversity jurisdiction existed since parties were from different states. However, upon reaching the Supreme Court, this decision was overturned with Justice Hugo Black writing for majority opinion emphasizing respect for finality of state-court judgments as well as avoiding unnecessary friction between both judicial systems.

In the dissenting opinion for Neely v. Martin K. Eby Construction Co., Inc., Justice Harlan disagreed with the majority's decision to reverse and remand the case back to lower courts, arguing that it was unnecessary and would only prolong litigation without any clear benefit. He contended that there was no need for a new trial as there were no substantial errors in jury instructions or evidentiary rulings during the original trial which could have affected its outcome significantly. Furthermore, he criticized the majority's interpretation of Federal Rule of Civil Procedure 50(b), stating that their reading of this rule was overly broad and not consistent with its intended purpose or historical application. In his view, allowing such an expansive interpretation would undermine judicial efficiency by encouraging needless appeals and retrials.