In the case of Belden v. Chase in 1893, the U.S Supreme Court was tasked with determining whether a New York law that allowed for the seizure and sale of imported goods to satisfy a tax lien violated federal laws governing customs duties. The dispute arose when Charles A. Belden, as sheriff of Erie County, seized certain goods belonging to William H. Chase under an execution issued upon a judgment recovered by John Ganson against said Chase for taxes due from him as receiver appointed by the United States Circuit Court for Southern District of New York. The court ruled in favor of Belden stating that once imported merchandise has been entered at customhouse; duties paid or secured according to law; taken possession by importer or his agent; it becomes part of mass property within state subjecting itself to local taxation and may be sold on execution against its owner without violating any provision or principle derived from Constitution or laws relating to revenue system established by Congress.

In the dissenting opinion for Belden v. Chase, Justice Brewer argued that the majority's decision was inconsistent with previous rulings and principles of equity. He contended that a mortgage is not an absolute conveyance of property but merely a security for debt, thus it should be treated as such in bankruptcy proceedings. The debtor still retains an interest in the mortgaged property which can be reached by other creditors if his personal estate is insufficient to satisfy their claims. Therefore, he disagreed with the majority's view that only surplus after payment of mortgage debt could be claimed by other creditors; instead all assets including those under mortgage should form part of bankrupt’s estate available to general creditors. Furthermore, he criticized the court's reliance on English law precedents while ignoring American jurisprudence favoring equitable distribution among all creditors.