In the 1908 case of Coder, Trustee of Armstrong, Bankrupt v. Arts, the United States Supreme Court dealt with a dispute over bankruptcy law and property rights. The trustee for bankrupt party Armstrong sought to recover certain real estate properties that had been transferred by Armstrong to defendant Arts prior to his declaration of bankruptcy. The trustee argued these transfers were fraudulent under federal bankruptcy law because they were made without receiving fair consideration in return and with intent to hinder or delay creditors' claims against him. However, the court ruled in favor of Arts stating that there was no evidence proving fraud on part of Armstrong when he transferred those properties before declaring bankruptcy. Therefore, it upheld the validity of those transactions and denied recovery claim by Coder.

In the dissenting opinion for CODER, TRUSTEE OF ARMSTRONG, BANKRUPT v. ARTS (1908), it was argued that the majority's decision to uphold a lower court ruling allowing Arts to retain property he had purchased from Armstrong before Armstrong declared bankruptcy was incorrect. The dissenting justices believed that this ruling contradicted previous decisions by the Supreme Court and other courts which held that transactions made in anticipation of bankruptcy could be voided if they were not made in good faith or with fair consideration. They contended that there was sufficient evidence to suggest such circumstances existed in this case and thus, Coder should have been allowed to recover the property on behalf of Armstrong's creditors. Furthermore, they disagreed with the majority’s interpretation of relevant laws regarding fraudulent conveyance and insolvency proceedings.