In the case of Chicago Deposit Vault Company v. McNulta, 1893, the U.S. Supreme Court ruled in favor of McNulta and upheld a lower court's decision that the Chicago Deposit Vault Co., which was incorporated under Illinois law but had its principal place of business in New York, could be sued by an out-of-state plaintiff (McNulta) in federal court based on diversity jurisdiction. The company argued it should not be considered a citizen of New York for purposes of diversity jurisdiction because it was chartered and incorporated only in Illinois. However, the Supreme Court disagreed stating that while corporations are primarily citizens where they are incorporated; they can also be deemed citizens where their main office is located or where most business transactions occur if different from state incorporation.

In the dissenting opinion for the case of Chicago Deposit Vault Company v. McNulta, Justice Brewer argued that there was no fraud involved in this case and therefore, it should not have been brought to court. He believed that the company had acted within its rights when it transferred assets to another corporation before declaring bankruptcy. According to him, these actions were taken as part of a legitimate business strategy aimed at protecting shareholders' interests during difficult financial times. Furthermore, he disagreed with the majority's interpretation of Illinois law regarding fraudulent conveyances and insisted that such laws did not apply in this situation because there was no intent to defraud creditors or evade debt obligations on part of the company's management team.