In the case of Baker et al. v. Schofield, Receiver of the Merchants' National Bank of Seattle in 1916, the U.S Supreme Court was tasked with determining whether a receiver appointed by a federal court could be sued without permission from that court. The plaintiffs were creditors who had obtained judgments against an insolvent national bank and sought to collect their debts from its receiver. They argued that they should not need permission to sue because they were seeking enforcement of existing judgments rather than new claims against the receivership estate. The Supreme Court disagreed and ruled in favor of Schofield, holding that leave must first be obtained before suing a federally-appointed receiver regardless if it's for enforcing an existing judgment or making new claims on assets under control by such receivership estates. This decision reinforced previous rulings which established this principle as necessary for maintaining orderly administration over properties held in trust during insolvency proceedings.

In the dissenting opinion for Baker et al. v. Schofield, it was argued that the majority's decision to uphold a lower court ruling allowing a receiver of an insolvent national bank to recover payments made by the bank prior to its insolvency was incorrect. The dissenting justices believed that this interpretation of federal banking law unfairly penalized innocent third parties who had no knowledge of the bank's financial situation and were simply conducting business in good faith. They contended that such transactions should be considered final once completed, unless there is evidence of fraud or collusion with intent to defraud creditors or preference shareholders. This view held that reversing these transactions after they have been completed undermines confidence in commercial dealings and disrupts normal business operations.