Tileston v. Ullman, a 1942 case, involved a Connecticut law that prohibited the use of contraceptives and the provision of medical advice on their use. The plaintiff, Tileston, was a doctor who sought to challenge this law as he believed it infringed upon his patients' rights to receive proper medical treatment. However, the Supreme Court dismissed his suit for lack of standing because he did not demonstrate any personal harm from enforcement of the statute; rather than asserting his own constitutional rights were violated by this law's existence or application, Tileston claimed an adverse effect on third parties (his patients). Thusly ruled out due to procedural grounds without addressing substantive issues surrounding contraceptive laws in Connecticut at that time.

In the dissenting opinion for Tileston v. Ullman, Justice Frank Murphy argued that the case should not have been dismissed on technical grounds of standing. He believed that Dr. Tileston had a legitimate interest in challenging Connecticut's law banning contraceptives as it directly impacted his ability to provide comprehensive medical advice and treatment to his patients. Furthermore, he contended that the potential harm faced by Dr. Tileston’s patients due to their inability to access contraceptive services was significant enough for them to challenge this law indirectly through their physician. Thus, according to Justice Murphy, both parties involved had sufficient legal standing and personal stake in this matter which warranted judicial review of Connecticut's contraception ban.