In United States v. Wilkins, the Supreme Court of the United States held that a state court could not issue an injunction against a federal officer in order to prevent him from executing his official duties. The case arose when John Wilkins, Jr., was appointed by President James Monroe as receiver of public moneys for lands ceded by Indian tribes in Indiana and Illinois. When he attempted to execute his office, several individuals sought an injunction from the Circuit Court of St. Clair County (Illinois) restraining him from doing so on grounds that they had prior rights to receive such payments under certain treaties with Indian tribes which were inconsistent with those made by Congress and approved by President Monroe. The Supreme Court ruled that since this was a matter within exclusive jurisdiction of Congress and the executive branch, it could not be interfered with or enjoined through action taken in any state court; thus affirming its earlier decision in McCulloch v Maryland (1819).

In United States v. Wilkins, the Supreme Court was asked to decide whether a state court had jurisdiction over a case involving an African American man who had been held in slavery and then moved into Ohio, which prohibited slavery. The majority opinion of the Court found that the state court did not have jurisdiction because it lacked authority to determine questions of freedom or servitude under federal law. Justice Johnson wrote a dissenting opinion arguing that Congress could not interfere with matters within the exclusive domain of states such as determining rights between individuals living within their borders; therefore, he argued that Ohio courts should be allowed to exercise their own judgment on this matter without interference from Congress or any other body outside its boundaries. He also noted that while there may be some constitutional issues at play here, they were beyond his scope as a justice and should instead be left for future consideration by legislators and policymakers.