In United States v. Norton, the United States Supreme Court addressed the issue of whether a federal court had the authority to issue an injunction against a state officer. The case involved a dispute between the United States and the State of California over the ownership of certain lands. The United States sought to enjoin the State of California from interfering with its possession of the lands. The Supreme Court held that a federal court had the authority to issue an injunction against a state officer in order to protect the rights of the United States. The Court reasoned that the United States was entitled to the same protection from state interference as any other litigant. The Court also noted that the federal government had the power to protect its own interests, and that the federal courts had the authority to issue injunctions to protect those interests. The Court concluded that the federal court had the authority to issue an injunction against the state officer in order to protect the rights of the United States.

In United States v. Norton, the Supreme Court was tasked with determining whether a federal district court had jurisdiction to hear an action brought by the United States against a defendant for damages resulting from his alleged violation of a contract between himself and another party. The majority opinion held that such jurisdiction did not exist because there was no allegation or proof of any act done in pursuance of any law of Congress, nor were there allegations that would bring the case within admiralty or maritime jurisdiction. Justice Field dissented on this point, arguing that since it is well established that contracts made under authority granted by Congress are subject to judicial enforcement in federal courts, then surely contracts which violate laws enacted by Congress should also be so enforceable. He further argued that if parties could escape liability simply because their actions violated Congressional enactments rather than being expressly authorized thereby, then those enactments would become practically useless as means for protecting public interests and enforcing private rights.