In the case of Sovereign Camp of the Woodmen of the World v. Bolin et al., 1938, the U.S Supreme Court was tasked with determining whether a fraternal benefit society could change its constitution to increase assessment rates without violating contractual obligations to existing members. The plaintiff, Mr. Bolin, argued that his contract with Woodmen prevented them from raising his rates without consent. However, Woodmen contended that their right to amend their constitution included changes in member assessments and benefits as long as they were applied equally among all members. The court sided with Woodmen stating that when Mr.Bolin joined he agreed to be bound by future amendments made according to established procedures within their constitution; thus consenting in advance for potential increases in assessment rates or decreases in benefits provided these changes were not discriminatory but applicable uniformly across all membership classes.

In the dissenting opinion for Sovereign Camp of the Woodmen of the World v. Bolin et al., Justice Black argued that there was no constitutional basis to prevent Alabama from applying its own laws in this case, which involved a dispute over an insurance claim. He contended that Alabama had every right to enforce its own statutes regarding fraternal benefit societies and their contracts with members, as it did not conflict with any federal law or constitutionally protected rights. Furthermore, he disagreed with the majority's interpretation of "impairment of contract," arguing that changes in state law do not necessarily constitute impairment if they are made within reasonable regulatory boundaries and serve a legitimate public interest. In his view, allowing states to regulate such matters would better protect citizens' interests than deferring jurisdiction to national organizations like Woodmen.