In the case of Eaton, Trustee in Bankruptcy of Luke v. Boston Safe Deposit and Trust Company, Trustee of Leighton (1915), the U.S Supreme Court ruled on a dispute involving bankruptcy law and trust property. The court held that when an individual declares bankruptcy, their interest in a trust can be used to satisfy creditors' claims if it is not specifically protected by state or federal law. In this particular case, Mr. Luke had declared bankruptcy but also had an interest in a testamentary trust created by his father's will which was managed by Boston Safe Deposit and Trust Company as trustee for him and his siblings. The court decided that since Massachusetts law did not protect such interests from being claimed by creditors during bankruptcy proceedings, Mr.Luke's share could be used to pay off his debts.

In the dissenting opinion for Eaton v. Boston Safe Deposit and Trust Company, it was argued that the majority's decision to uphold a lower court ruling in favor of Boston Safe Deposit and Trust Company was incorrect. The dissenting justices believed that Luke, who had declared bankruptcy, should have been allowed to keep his property despite owing money to Leighton. They contended that the law did not clearly state whether or not a debtor could retain their property after declaring bankruptcy if they still owed money on it. Furthermore, they disagreed with the majority's interpretation of "fraudulent conveyance," arguing instead that Luke’s transfer of assets into trust before filing for bankruptcy did not constitute fraud under Massachusetts law as he received fair consideration for those transfers at market value rates from an independent third party (the trust). Therefore, these transactions were legitimate business decisions rather than attempts to defraud creditors.