In the case United States v. Burnison et al., 1949, the Supreme Court ruled on whether a federal court could issue an injunction to prevent state officials from enforcing a state law that was allegedly in violation of the U.S. Constitution. The defendants were members of California's State Oil and Gas Supervisor office who had issued orders restricting oil production under a California statute designed to prevent waste and protect correlative rights of producers in common pools of oil or gas. The plaintiffs argued these restrictions violated their constitutional rights by depriving them of property without due process and taking private property for public use without compensation. The Supreme Court held that federal courts have no jurisdiction over such cases unless it is shown that there is no adequate remedy at law available within the states themselves, which was not demonstrated here. Therefore, they upheld lower court decisions denying injunctive relief against enforcement actions taken by state officers under color of state law regulating production from marginal wells.

The dissenting opinion in the United States v. Burnison case argued that the majority's decision to uphold a law allowing for warrantless arrests on mere suspicion of crime was unconstitutional and violated citizens' Fourth Amendment rights against unreasonable searches and seizures. The dissenters believed that such an arrest without a warrant should only be permissible when there is probable cause, not just suspicion, to believe that a person has committed or is committing a crime. They contended that this interpretation would better protect individual liberties while still providing adequate power for law enforcement agencies to perform their duties effectively. Furthermore, they expressed concern about potential abuses of power by police officers if allowed to make arrests based solely on suspicion rather than concrete evidence or reasonable grounds.