In the United States v. Barnett et al., 1963, the U.S. Supreme Court ruled in favor of the federal government against Mississippi Governor Ross Barnett and Lieutenant Governor Paul B. Johnson Jr., who had defied a court order to allow James Meredith, an African American student, to enroll at the University of Mississippi (Ole Miss). The state officials were charged with civil contempt for their refusal to comply with federal law and faced potential penalties including fines or imprisonment if they continued their defiance. The case was significant as it reaffirmed that states must adhere to federal laws under the Supremacy Clause of the Constitution even when those laws conflict with state policies or practices - in this instance relating specifically to racial segregation in education.

In the dissenting opinion for United States v. Barnett et al., Justice Harlan argued that the majority's decision to uphold federal intervention in Mississippi was an overreach of judicial power. He contended that while he agreed with the goal of ending racial discrimination, it should not be achieved by violating states' rights and ignoring constitutional limits on federal authority. Harlan believed that Congress did not have unlimited power to enforce civil rights under the Fourteenth Amendment, particularly when it came to regulating private conduct or intruding upon state sovereignty. He also expressed concern about setting a dangerous precedent where courts could intervene in local affairs whenever they deemed necessary without clear constitutional authorization.