In the 1911 case of Henderson, Trustee in Bankruptcy of Burns v. Mayer, the United States Supreme Court dealt with a dispute over property rights and bankruptcy law. The trustee for Mr. Burns' bankrupt estate, Mr. Henderson, sued to recover certain properties that had been transferred by Burns prior to his declaration of bankruptcy on grounds that these transfers were fraudulent and intended to hinder creditors from accessing assets they were owed. However, Mayer argued he was an innocent purchaser who bought the properties without knowledge of any fraud or intent to defraud creditors on part of Burns. The court ruled in favor of Mayer stating that under Section 67e (now §548) of the Bankruptcy Act which allows trustees to set aside fraudulent conveyances within one year before filing for bankruptcy; it does not apply when a bona fide purchaser has acquired rights in good faith without notice or reasonable cause to believe such transfer is voidable against creditors as per state laws where transaction occurred. This decision clarified how federal bankruptcy law interacts with state property laws regarding fraudulent transfers and established precedent protecting innocent purchasers who acquire property without knowledge or reason to suspect fraudulence involved in its previous transactions.

In the dissenting opinion for Henderson, Trustee in Bankruptcy of Burns v. Mayer (1911), Justice Holmes argued that the majority's decision was based on a misinterpretation of bankruptcy law and its application to property rights. He contended that when an individual declares bankruptcy, their assets should be distributed among creditors according to state laws unless federal legislation explicitly states otherwise. In this case, he believed that the bankrupt party's right to redeem his mortgaged property had been unfairly disregarded by the court because it did not fit into traditional categories recognized under common law principles. This right should have been considered part of his estate and therefore subject to distribution among his creditors rather than being automatically extinguished upon declaration of bankruptcy as determined by the majority ruling.