In the Supreme Court case of Virginia v. Friedman in 1987, the court addressed whether a state could require an attorney to be a resident in order to practice law within that state. The plaintiff, Howard R. Friedman, was an attorney who lived and practiced law in Washington D.C., but also maintained an office for his legal practice in Virginia where he was licensed to practice as well. However, due to residency requirements imposed by the State Bar of Virginia and upheld by the Supreme Court of Virginia which required attorneys practicing within its jurisdiction to reside there or maintain a bona fide office therein (meaning it must be their principal place for practicing), Mr. Friedman's license was suspended. The U.S Supreme Court ruled against this requirement stating that such restrictions violated both Privileges and Immunities Clause and Commerce Clause under Article IV Section 2 & Article I Section 8 respectively of US Constitution because they discriminated against non-resident lawyers without serving any substantial state interest thereby creating unnecessary barriers on interstate commerce.

In the dissenting opinion for Supreme Court of Virginia et al. v. Friedman, Justice White disagreed with the majority's ruling that a state law requiring nonresident attorneys to associate with local counsel in order to practice in Virginia courts was unconstitutional under the Privileges and Immunities Clause. He argued that states have a substantial interest in regulating their own legal systems, including ensuring effective representation by lawyers who are familiar with local rules and procedures. The association requirement served this purpose without unduly burdening out-of-state attorneys or discriminating against them solely based on residency status. Furthermore, he contended that there were other less restrictive means available for nonresident lawyers to gain admission before Virginia courts such as pro hac vice admission or becoming members of the state bar themselves.