In the 1995 case of William Field and Norinne Field v. Philip W. Mans, the U.S Supreme Court addressed a dispute over a real estate contract in Vermont. The Fields had sold land to Mans but later sued him for breach of contract when he failed to make agreed-upon payments. The main issue was whether federal or state law should apply in determining if an installment land sale contract is considered a "security agreement" under Article 9 of the Uniform Commercial Code (UCC). If it were deemed as such, then certain protections would be afforded to sellers like the Fields upon buyer's defaulting on payment terms. The court ruled that state law should govern this determination rather than federal common law because there was no significant federal interest at stake that warranted overriding state laws governing commercial transactions. Therefore, since Vermont did not consider such contracts as security agreements under its interpretation of UCC Article 9, the Fields could not claim those specific protections against Mans' default.

In the dissenting opinion for William Field and Norinne Field v. Philip W. Mans, Justice Ginsburg disagreed with the majority's interpretation of Section 523(a)(2)(A) of the Bankruptcy Code. She argued that this section should not be read to exclude all representations about a debtor's financial condition from its scope unless they are in writing, as it would create an unwarranted loophole for dishonest debtors who orally misrepresent their financial status to obtain credit or goods on false pretenses. Instead, she proposed that only statements respecting a debtor’s overall net worth or overall income flow should require written documentation under §523(a)(2). This approach would better align with Congress' intent to prevent abuse while still protecting honest debtors seeking relief through bankruptcy.