In the 1946 case of COPE v. ANDERSON, RECEIVER, the United States Supreme Court dealt with a dispute over oil and gas royalties between Cope (the lessor) and Anderson (the lessee). The lease agreement stipulated that if production ceased for any reason, it could be maintained by paying a delay rental until production resumed. However, during World War II, government regulations prohibited drilling operations which led to cessation of production. Anderson continued to pay delay rentals as per contract but Cope argued this was not sufficient to maintain the lease since cessation was due to external factors beyond control of either party. The court ruled in favor of Anderson stating that payment of delay rentals according to terms agreed upon in their contract kept the lease alive even though actual drilling had stopped due to governmental restrictions.

In the dissenting opinion for COPE v. ANDERSON, it was argued that the majority's decision to allow a receiver to take control of property in another state without obtaining leave from the court which appointed him contradicted previous rulings and principles of comity among states. The dissent emphasized that receivers are officers of the appointing court and their authority should not extend beyond its jurisdiction unless permitted by courts in other jurisdictions where they seek to exercise power. It was also pointed out that this ruling could potentially lead to conflicts between federal and state authorities, as well as between different states' courts if multiple receivers were appointed over assets located in various jurisdictions. Furthermore, it was contended that allowing such an extension of a receiver’s powers would undermine respect for judicial boundaries and disrupt orderly legal processes.