In the case of Wallace et al. v. Hines, Director General of Railroads, et al., 1919, the U.S Supreme Court was tasked with determining whether a federal court could enjoin state officials from enforcing state laws that were allegedly in conflict with acts of Congress and orders by administrative bodies authorized by Congress. The plaintiffs argued that certain Alabama tax laws violated their rights under federal law as they pertained to railroad property leased by the United States during World War I. The Supreme Court held that while it is generally true that no one can be restrained from instituting proceedings in any court until judgment has been rendered against him or her and he or she threatens to execute it illegally, there are exceptions when enforcement would infringe upon federally protected rights or interfere with national policy objectives set forth through legislation or executive action.

The dissenting opinion in the case of Wallace et al. v. Hines, Director General of Railroads, et al., argued that the federal government's control over railroads during World War I did not absolve them from state laws and regulations. The dissenters believed that while Congress had given the President power to take possession and assume control of any system or systems of transportation for national security purposes, this did not mean they were exempt from adhering to state laws regarding employee working hours. They contended that such a broad interpretation would undermine states' rights and upset the balance between federal and state powers established by the Constitution. Furthermore, they asserted that there was no explicit provision in Congressional legislation stating an intent to supersede these types of state laws when taking over railroads for wartime needs.