In the case of Chicago, Milwaukee and St. Paul Railway Company v. Bosworth, Receiver in 1900, the U.S Supreme Court ruled on a dispute involving railway freight charges. The plaintiff was a receiver for several insolvent companies who had shipped goods via the defendant's rail line but failed to pay their freight bills due to bankruptcy proceedings. The defendant railroad company claimed that it should be paid from funds held by the receiver before any other creditors because its services were necessary for preserving and enhancing value of assets under receivership (i.e., they argued they had priority status). However, this claim was rejected by both lower courts and eventually by the Supreme Court as well which upheld previous rulings stating that common carriers like railroads do not have automatic preferential rights over other creditors when dealing with insolvent shippers' estates unless there is an explicit contract or statute granting such preference.

In the dissenting opinion for the case of Chicago, Milwaukee and St. Paul Railway Company v. Bosworth, Receiver (1900), it was argued that there were significant issues with how the majority interpreted certain aspects of law related to bankruptcy proceedings. The dissent disagreed with the majority's view that a receiver in bankruptcy could not be held liable for damages caused by negligence during their tenure because they acted as an arm of the court rather than an independent entity. They believed this interpretation undermined accountability and failed to provide adequate protection or recourse for those harmed by such negligence. Furthermore, they contended that this ruling contradicted previous decisions where receivers had been found liable under similar circumstances.