In the 1929 case Early, Receiver v. Richardson, the United States Supreme Court ruled on a dispute involving bankruptcy and property rights. The respondent, Richardson, had purchased land from a company that later went bankrupt. The petitioner, Early (the receiver of the bankrupt company), claimed that because the sale was not recorded until after bankruptcy proceedings began, it should be considered void and thus part of the assets to be distributed among creditors. However, under local law in Washington D.C., where this took place - an unrecorded deed is still valid between parties involved in its creation or those with notice about it; therefore making Richardson's purchase legitimate despite late recording. The Supreme Court upheld this principle by ruling in favor of Richardson stating that he held rightful ownership over his purchased land as per local laws even though it wasn't immediately recorded at time of transaction before bankruptcy filing occurred for selling party/company.

In the dissenting opinion for Early v. Richardson, it was argued that the majority's decision to allow a receiver appointed by a federal court in one state to sue in another without ancillary receivership contradicted previous rulings and principles of comity among states. The dissent emphasized that such an action should only be permitted if there is evidence of fraud or collusion, which was not present in this case. It also pointed out that allowing such suits could lead to conflicting judgments between different courts and undermine the authority of local courts over property within their jurisdiction. Furthermore, it contended that permitting these actions would create unnecessary litigation costs and delays as parties are forced to defend themselves in distant jurisdictions rather than where they reside or where their assets are located.