In the 1906 case of Cunningham v. Springer, the U.S Supreme Court was tasked with determining whether a Nevada law that allowed for the seizure and sale of property to satisfy tax debts violated due process rights under the Fourteenth Amendment. The appellant, Cunningham, argued that his property had been unlawfully seized and sold by Springer without proper notice or opportunity to be heard in court. The Supreme Court disagreed with this argument, ruling that there was no violation of due process rights as long as state laws provided an adequate remedy for wrongful seizures. In this instance, Nevada law did provide such a remedy through its provision allowing individuals whose properties were wrongfully seized to sue county treasurers who carried out these seizures. Therefore, since Cunningham could have pursued legal action against Springer within their own state's judicial system but chose not to do so before taking his case directly to federal courts instead; he failed in proving any infringement on his constitutional rights.

In the dissenting opinion for Cunningham v. Springer, Justice Harlan argued that the majority's decision was a departure from established principles of law and equity. He contended that it was incorrect to assert that a corporation could not be held accountable for fraudulent actions committed by its officers if those actions were beyond their authority as defined in the company's charter. Harlan believed this interpretation allowed corporations to evade responsibility for fraud perpetrated on their behalf, which he saw as contrary to both legal precedent and public policy. He also disagreed with the majority's view regarding estoppel, arguing instead that an innocent party who had been defrauded should not be prevented from seeking redress simply because they had initially trusted in false representations made by corporate officers.