In Bailey, Assignee v. Glover et al., the Supreme Court of the United States was asked to decide whether a state court had the authority to issue a writ of attachment against a defendant who was a non-resident of the state. The plaintiff, Bailey, was the assignee of a judgment obtained in a state court against Glover and others. The plaintiff sought to enforce the judgment by obtaining a writ of attachment from the state court against the defendants, who were non-residents of the state. The defendants argued that the state court did not have the authority to issue the writ of attachment against them because they were non-residents. The Supreme Court held that the state court did have the authority to issue the writ of attachment against the defendants. The Court reasoned that the state court had the power to issue the writ of attachment because the defendants had sufficient contacts with the state to justify the exercise of jurisdiction. The Court noted that the defendants had sufficient contacts with the state to justify the exercise of jurisdiction, including the fact that the defendants had been served with process in the state and had appeared in the state court. The Court concluded that the state court had the authority to issue the writ of attachment against the defendants.

In the case of Bailey, Assignee v. Glover et al., Justice Field delivered a dissenting opinion in which he argued that the majority had misinterpreted the Bankruptcy Act of 1867 and failed to recognize Congress’s intent when it passed this law. He noted that Congress intended for bankruptcies to be handled uniformly throughout all states, but by allowing state laws to supersede federal bankruptcy laws, as was done in this case, would lead to different outcomes depending on where a debtor resided. Furthermore, Justice Field argued that if creditors were allowed to take advantage of state exemptions from bankruptcy proceedings then they could use those exemptions strategically against debtors who are unable or unwilling to move out-of-state during their bankruptcy process. Ultimately, Justice Field concluded that such an interpretation would undermine Congress’s original intention with regards to uniformity and fairness within the nation's bankruptcy system.