The U.S. Supreme Court case Fort Smith & Western Railroad Company et al. v. Mills, Receiver of Fort Smith & Western Railroad Company, et al., 1919 revolved around the issue of whether a receiver appointed by a federal court could be held liable for damages caused by negligence during his tenure in managing the railroad company's property and operations. The plaintiffs argued that since the receiver was acting under authority granted by the court, he should bear responsibility for any harm resulting from his actions or lack thereof. However, the defendant contended that as an agent of the court, he was immune to such claims unless they were approved by said court first. In its decision, The Supreme Court ruled in favor of Mills (the receiver), stating that receivers operating under federal courts are indeed shielded from liability unless permission is given directly from those courts to pursue legal action against them - essentially granting them judicial immunity while performing their duties as receivers.

The dissenting opinion in the case of Fort Smith & Western Railroad Company v. Mills argued that the majority's decision to allow a receiver appointed by an Oklahoma court to take control of property located in Arkansas was incorrect. The dissenters believed this violated principles of federalism and state sovereignty, as it allowed one state's courts to exercise authority over property located within another state’s jurisdiction. They contended that while receiverships are often necessary for insolvent corporations, they should not be used as a means for one state to interfere with another’s rights or properties. Furthermore, they asserted that allowing such actions could lead to confusion and conflict between states' laws and jurisdictions which would ultimately undermine the stability and predictability needed in legal matters involving interstate commerce.