In the case of Fidelity Title & Trust Company, Ancillary Administrator of Pancoast v. DuBois Electric Company in 1919, the Supreme Court was asked to determine whether a state court had jurisdiction over an out-of-state corporation that did not have any property or business within the state. The plaintiff argued that because they were able to serve notice on one of the company's officers while he was temporarily in Connecticut for unrelated matters, this gave them sufficient grounds for jurisdiction. However, the defendant contended that merely serving notice on an officer who happened to be passing through Connecticut did not establish substantial contact with the state and therefore could not confer jurisdiction. The Supreme Court ruled in favor of DuBois Electric Company stating that mere service upon a non-resident officer temporarily within a State does not give local courts authority over his corporation which has no office or place of business there nor is doing any corporate act there when served. This decision clarified rules regarding personal jurisdiction and established precedent about what constitutes "doing business" within a particular location.

In the dissenting opinion for Fidelity Title & Trust Company v. Dubois Electric Company, Justice Louis Brandeis argued that the majority's decision was inconsistent with previous rulings and principles of equity. He contended that a creditor should not be allowed to seize assets from an insolvent debtor if it would leave other creditors without any means of recovery. In this case, he believed that allowing Dubois Electric Company to take all of Pancoast's property as payment for its debt would unfairly disadvantage other creditors who also had valid claims against Pancoast’s estate. Furthermore, he disagreed with the majority's interpretation of Pennsylvania law regarding liens and insolvency proceedings, arguing instead that state law intended to ensure equitable distribution among all creditors in cases like these.