In the United States v. Raines et al., 1959, the Supreme Court ruled that a federal law designed to protect African Americans' right to vote was constitutional and could be enforced against state officials. The case involved several Georgia county officials who were charged with preventing black citizens from voting in a primary election. They argued that they couldn't be prosecuted under this law because it was unconstitutional, claiming it violated states' rights by interfering with their ability to regulate elections. However, the Supreme Court disagreed and upheld the constitutionality of this law (the Civil Rights Act of 1957), asserting that Congress had authority under the Fifteenth Amendment to prevent racial discrimination in voting.

In the dissenting opinion for United States v. Raines et al., Justice Whittaker disagreed with the majority's decision to uphold a federal law that allowed prosecution of state officials who violated civil rights. He argued that this interpretation was too broad and could potentially infrive on states' rights, as it would allow federal courts to intervene in local matters even when no specific individual had been harmed or threatened by discriminatory practices. Furthermore, he contended that there were insufficient grounds for invoking jurisdiction under the Fourteenth Amendment because not all defendants were acting under color of state law at the time of their alleged offenses. In his view, only those individuals who held public office should be subject to penalties under this statute; private citizens engaging in similar behavior did not fall within its scope.