In the case of Sun Printing and Publishing Association v. Edwards in 1903, the U.S Supreme Court ruled on a matter concerning copyright law. The plaintiff, Sun Printing and Publishing Association, alleged that their competitor had infringed upon their copyright by reprinting news articles from their publication without permission. However, the defendant argued that they were not infringing because they only reprinted factual information from these articles which cannot be copyrighted under US law. The court sided with the defendant stating that facts or information per se are not protected by copyright laws; rather it is how those facts are expressed or arranged that can be copyrighted. Therefore, as long as one does not copy another's unique expression of an idea but merely uses its factual content for creating something new or different, there would be no infringement of copyright laws.

In the dissenting opinion for SUN PRINTING AND PUBLISHING ASSOCIATION v. EDWARDS, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and violated principles of federalism. He contended that it was not within the jurisdiction of a federal court to interfere in a state court matter unless there were constitutional issues at stake. In this case, he believed no such issues existed as it pertained to an employment contract dispute between Edwards and Sun Printing and Publishing Association. Furthermore, he emphasized that New York courts had already ruled on this issue based on their own laws which should be respected by federal courts under principles of comity among states. Thus, according to him, granting an injunction against enforcement of a judgment from New York’s highest court overstepped boundaries set by prior Supreme Court decisions regarding respect for state law judgments.