In the case of State of Wisconsin on the Relation of Bolens v. Frear, Secretary of State of the State Of Wisconsin (1913), plaintiff Bolens challenged a state law that required voters to publicly declare their party affiliation before participating in primary elections. The Supreme Court upheld this law, ruling it did not violate any constitutional rights and was within states' powers to regulate their own electoral processes. The court reasoned that public declaration is necessary for maintaining integrity in partisan primaries by preventing members from opposing parties from interfering with candidate selection. This decision affirmed states' authority over election procedures while also setting precedent for future cases involving voter privacy and freedom association.

In the dissenting opinion for the case of State of Wisconsin on the Relation of Bolens v. Frear, Justice Holmes argued that it was not within the Court's jurisdiction to interfere with a state's internal affairs unless there is clear violation of constitutional rights. He believed that this case did not present such a situation and therefore, he disagreed with his colleagues' decision to strike down Wisconsin’s law requiring corporations to pay an annual license fee based on their capital stock as unconstitutional. According to him, states should have broad discretion in determining how they raise revenue and regulate businesses within their borders without interference from federal courts unless these actions clearly infringe upon constitutionally protected rights or interests.