In the 1995 case of Citizens Bank of Maryland v. David Strumpf, the U.S. Supreme Court ruled unanimously that a bank did not violate federal law when it froze a customer's account without first providing notice or an opportunity to dispute the action. The case arose after Mr. Strumpf filed for bankruptcy and his bank, Citizens Bank of Maryland, temporarily froze his accounts in response to offset what he owed them against funds in those accounts - a common practice known as "setoff". Mr. Strumpf argued this violated automatic stay provisions under bankruptcy law and due process rights under the Constitution by depriving him access to his money without prior notice or hearing. The court disagreed with Mr.Strumpf’s argument stating that temporary freeze was not effectively controlling debtor's property but merely preserving status quo until setoff could be accomplished properly; hence no violation occurred on part of bank regarding automatic stay provision nor due process clause.

In the dissenting opinion for Citizens Bank of Maryland v. David Strumpf, Justice Ginsburg argued that the bank's temporary freeze on Strumpf's account constituted a breach of its duty as a fiduciary to act in good faith and with due regard for his interests. She contended that by freezing his account without notice or opportunity to be heard, the bank effectively deprived him of access to his own funds and violated fundamental principles of fairness. Furthermore, she disagreed with the majority's view that this action was justified under bankruptcy law provisions allowing creditors to set off mutual debts; instead, she believed these provisions were intended only as a last resort measure when debtors default on their obligations. In her view, applying them in this case would undermine debtor protections built into bankruptcy law and could potentially encourage other banks to engage in similar practices.