In United States v. Andrew Hodge, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by the United States against a citizen of another state. The case arose when Andrew Hodge, a resident of Virginia, was sued in Georgia for failing to pay taxes on goods he had imported into that state from abroad. Hodge argued that since he was not a resident of Georgia and did not have any property there, the Georgia court lacked jurisdiction over him and could not compel him to appear or answer its complaint. The Supreme Court disagreed with this argument and held that it is within the power of Congress to grant authority to states courts in such cases involving citizens from other states who are subjecting themselves voluntarily or involuntarily under their laws. As such, they concluded that Georgia's courts were authorized by Congress' act granting them jurisdiction over non-residents like Hodge and thus affirmed his conviction for failing to pay taxes on his imports into the state.

In United States v. Andrew Hodge, the Supreme Court was asked to decide whether a federal court had jurisdiction over an alleged violation of a state law. The majority opinion held that it did not have such jurisdiction and dismissed the case for lack of subject matter jurisdiction. Justice McLean dissented from this decision, arguing that Congress has authority under Article III of the Constitution to vest in federal courts exclusive cognizance over certain cases arising out of state laws. He argued further that since Congress had done so in this instance by passing legislation granting exclusive original cognizance to all suits brought against any person who shall be guilty of any act or omission prohibited by any statute passed by either house of Congress, then the federal court should have been able to hear this case involving an alleged violation of a state law.