The Commercial Trust Company of New Jersey v. Miller case in 1922 revolved around the seizure and sale of enemy-owned property during World War I under the Trading with the Enemy Act. The plaintiff, Commercial Trust Company, argued that it was a bona fide mortgagee for value without notice and thus its rights should not be affected by the Alien Property Custodian's actions. However, defendant A. Mitchell Palmer as Alien Property Custodian contended that he had full authority to seize such properties regardless of any existing mortgages or liens on them. The Supreme Court ruled in favor of Miller (the Alien Property Custodian), stating that his powers were absolute and unqualified under wartime legislation passed by Congress. It held that when an alien enemy's property is seized under this act, all previous claims against it are extinguished unless specifically exempted by Congress itself - which did not apply here since there was no exemption for innocent lienholders like Commercial Trust Company. This decision underscored how far-reaching government powers can be during times of war; even private contracts may become secondary to national security interests.

In the dissenting opinion for Commercial Trust Company of New Jersey v. Miller, Justice Holmes argued that the majority's decision was a departure from established principles of international law and could potentially harm U.S. interests abroad. He contended that under international law, enemy aliens have no rights except those given by the country in which they find themselves during war time. Therefore, he believed it was wrong to allow an enemy alien to maintain a lawsuit in American courts during World War I without express permission from Congress or the President. Furthermore, he expressed concern about reciprocity; if America denied such rights to foreign nationals on its soil during wartime, other nations might do likewise with Americans abroad under similar circumstances.