In the United States v. Price et al., 1965, the Supreme Court ruled that state officials who conspired to deprive individuals of their constitutional rights could be prosecuted under federal law. The case was related to the murder of three civil rights workers in Mississippi in 1964 by a group including local law enforcement officers and members of the Ku Klux Klan. Initially, charges against all defendants were dismissed on grounds that they acted as private citizens rather than under color of state law. However, upon appeal to the Supreme Court, it held that these actions fell within federal jurisdiction because they involved misuse of power possessed by virtue of state law and made possible only because wrongdoer is clothed with authority from state laws; thus reversing lower court's decision.

In the dissenting opinion for United States v. Price et al., Justice Potter Stewart argued that the majority's interpretation of the Fourteenth Amendment was too broad and could potentially lead to federal overreach into state matters. He contended that while he agreed with their intent to prosecute those who violated civil rights, he believed this should be done within a framework that respected states' rights and jurisdictional boundaries as outlined in the Constitution. In his view, by allowing federal prosecution of private individuals for crimes committed on state property without clear evidence of state involvement or abdication of duty, they were setting a dangerous precedent which could undermine principles of federalism and blur lines between local law enforcement responsibilities and national government authority.