In the 1892 case of Scott v. Armstrong, the US Supreme Court ruled in favor of defendant Armstrong, a postmaster who had been sued by plaintiff Scott for allegedly withholding mail and thus interfering with his business operations. The court found that as a federal officer, Armstrong was protected from such lawsuits under federal law if he was acting within his official capacity and without malice or negligence. In this instance, it was determined that there were no grounds to prove either malice or negligence on part of Armstrong; rather he acted upon instructions received from superiors regarding suspected fraudulent activities related to Scott's mails. Therefore, the court held that any grievances against actions taken by federal officers like postmasters should be addressed through administrative channels instead of private lawsuits.

In the dissenting opinion for Scott v. Armstrong, Justice Brewer argued that the majority's decision was a misinterpretation of the law and an overreach of judicial power. He contended that it was not within their jurisdiction to decide on matters related to property rights or contracts between private parties unless there is a clear violation of federal law or constitutional rights involved. In this case, he believed that no such violation had occurred and therefore, they should have deferred to state courts' judgment instead. Furthermore, he criticized the majority for ignoring established legal principles in favor of creating new ones based on their own personal beliefs about what constitutes fair business practices. This approach, according to him, undermines legal certainty and predictability which are essential elements in any functioning legal system.