In the case of Burke v. American Loan and Trust Company, 1894, the U.S Supreme Court was tasked with determining whether a foreclosure sale could be set aside due to an inadequate purchase price. The plaintiff, Burke, had defaulted on his mortgage payments which led to a foreclosure by the defendant company. However, he argued that the property's selling price at auction was significantly lower than its fair market value and thus unfair. The court ruled in favor of American Loan and Trust Company stating that inadequacy of price alone is not sufficient grounds for setting aside a judicial sale unless it is so gross as to shock one’s conscience or there are additional circumstances indicating fraud or unfairness in some way related to the low sales price.

In the dissenting opinion for Burke v. American Loan and Trust Company, it was argued that the majority's decision failed to adequately consider the rights of creditors in bankruptcy proceedings. The dissenting justices believed that a debtor should not be allowed to discharge their debts without first providing adequate notice to all affected parties, including those who may have claims against them. They contended that this principle is fundamental to due process and fairness within the legal system. Furthermore, they disagreed with the majority's interpretation of relevant federal statutes on bankruptcy procedures, arguing instead for an interpretation which would better protect creditors' interests while still allowing debtors a fair opportunity for financial recovery.