In the case of Chase Manhattan Bank (National Association) v. South Acres Development Co., 1977, the Supreme Court ruled in favor of Chase Manhattan Bank. The dispute arose when South Acres Development Company defaulted on a loan from Chase Manhattan Bank and filed for bankruptcy protection under Chapter XI of the Federal Bankruptcy Act. In response, Chase sought to foreclose on property owned by South Acres that was pledged as collateral for the loan. However, an automatic stay provision in Chapter XI prevented them from doing so without court permission. The Supreme Court held that this provision did not apply to secured creditors like banks who were seeking to enforce their rights against collateral outside of bankruptcy proceedings - thus allowing foreclosure actions by such creditors even during ongoing bankruptcy cases.

In the dissenting opinion for Chase Manhattan Bank v. South Acres Development Co., Justice Stevens argued that the majority's decision to uphold a Texas statute limiting out-of-state banks' ability to enforce liens in Texas was inconsistent with previous rulings on interstate commerce. He contended that this law unfairly discriminated against non-Texas creditors, thus violating the Commerce Clause of the Constitution. Furthermore, he disagreed with the majority's view that banking was not considered "commerce" under constitutional law and pointed out several past cases where it had been treated as such. Finally, he expressed concern over how this ruling could potentially encourage other states to enact similar protectionist laws, further hindering interstate commerce and undermining national economic unity.