In the 1939 case of United States v. United States Fidelity & Guaranty Co., the Supreme Court ruled on a matter involving federal jurisdiction and insurance claims. The U.S government had filed suit against an insurance company to recover damages for a mail truck that was involved in an accident with another vehicle insured by the defendant. The question before the court was whether or not this constituted a federal claim, as it would determine which court system (federal or state) had jurisdiction over such cases. In its decision, the Supreme Court held that because there were no specific provisions in any act of Congress providing for suits by the United States on direct liability policies issued under state laws, these types of lawsuits did not arise under U.S law and therefore fell outside federal jurisdiction. This meant that such cases should be heard in state courts rather than at a federal level.

In the dissenting opinion for United States v. United States Fidelity & Guaranty Co., Justice Black argued that the majority's decision was inconsistent with previous rulings and principles of statutory interpretation. He contended that Congress intended to include government corporations within the definition of "person" in Section 1 of Sherman Act, as it had done so explicitly in other statutes around the same time period. Furthermore, he pointed out that this interpretation would not lead to absurd results or interfere with governmental functions, as feared by the majority. Instead, exempting such entities from antitrust laws could potentially allow them to engage in monopolistic practices without any legal repercussions - a result clearly contrary to Congressional intent when enacting these laws. Thus, he disagreed with the court's ruling which held otherwise.