In the 1959 case of Superior Court of Washington for King County et al. v. Washington ex rel. Yellow Cab Service, Inc., the U.S Supreme Court dealt with a dispute over jurisdiction in relation to an anti-trust lawsuit brought by Yellow Cab Service against several taxi companies and individuals in Seattle, alleging that they conspired to monopolize trade and commerce contrary to state law. The defendants sought removal of the case from state court to federal court on grounds that it arose under federal antitrust laws; however, this was denied by both district and appellate courts. The Supreme Court affirmed these decisions, ruling that just because conduct might violate both state and federal law does not automatically mean a case arises under both jurisdictions - there must be a substantial claim based directly on federal law for jurisdictional purposes. In this instance, while similar principles were involved at both levels (i.e., prohibition of monopoly), the plaintiff's right being enforced was created solely by state statute without any reference or reliance upon its counterpart in Federal legislation.

In the dissenting opinion for Superior Court of Washington for King County et al. v. Washington ex rel. Yellow Cab Service, Inc., Justice Frankfurter argued that the majority's decision to allow a state court to exercise jurisdiction over an out-of-state defendant based on their contractual relationship with an in-state plaintiff was inconsistent with due process principles and previous Supreme Court precedents. He contended that such a broad interpretation of personal jurisdiction could potentially subject any person or corporation who enters into a contract affecting interstate commerce to litigation in any state where the contract has effects, regardless of whether they have meaningful contacts or affiliations with those states. This, he believed, would create undue burdens on interstate business activities and undermine legal certainty by making it difficult for parties to predict where they might be sued.