In the 1930 case of Stange v. United States, the Supreme Court examined whether a federal court in one state could issue an injunction to prevent a lawsuit from being filed in another state's courts. The plaintiff, Stange, had previously sued for damages against several railroad companies and their employees in Illinois after his wife was killed at a railway crossing. While that suit was pending, he also initiated proceedings against the same defendants in Missouri under its wrongful death statute. The railroads sought an injunction from the federal district court where they were first sued (Illinois) to stop Stange from proceeding with his second action (Missouri). They argued that this would constitute "vexatious litigation." However, Justice Holmes delivered the opinion of the Court stating that while it is possible for Federal Courts to enjoin parties before them from prosecuting actions elsewhere under certain circumstances; such power should be used sparingly and only when necessary to protect jurisdiction or avoid multiplicity of suits causing inequity among parties involved.

The dissenting opinion in the case of Stange v. United States argued that the majority's decision to uphold a conviction based on circumstantial evidence was flawed. The dissenting justices believed that there were too many uncertainties and potential alternative explanations for the evidence presented, making it insufficient to prove guilt beyond a reasonable doubt. They contended that while circumstantial evidence can be used effectively in some cases, its use should be limited and carefully scrutinized due to its inherent ambiguity. In this particular case, they felt that such scrutiny had not been applied adequately by either the trial court or their fellow Supreme Court Justices. Therefore, they disagreed with affirming Mr.Stange’s conviction solely based on indirect proof without any direct testimony implicating him in illegal activities.