In the case of Holder v. Aultman, the U.S. Supreme Court ruled in 1897 that a corporation cannot unilaterally dissolve itself without settling its existing debts and liabilities. The dispute arose when Mr. Holder purchased assets from Aultman & Taylor Machinery Company after it had attempted to dissolve itself and distribute its property among shareholders without paying off creditors first, including Mr. Holder who held unpaid notes from the company's sales of machinery on credit terms before dissolution was initiated by shareholders' resolution but not completed legally under Ohio law at that time which required court approval for voluntary dissolution after notice to creditors and provision for their claims. The Supreme Court found this attempt at self-dissolution invalid as it violated rights of corporate creditors like Mr. Holder whose claim remained unsatisfied while corporate assets were distributed among stockholders instead of being applied first to pay off corporate debts as per general rule in equity jurisprudence applicable also under Ohio law then. Thus, despite purported dissolution by shareholder action alone, the corporation continued to exist de jure until properly dissolved through due legal process ensuring protection of creditor rights against unjust deprivation caused by premature distribution or diversion of corporate assets away from debt settlement obligations inherent in every business entity's existence whether solvent or insolvent.

In the dissenting opinion for Holder v. Aultman, Justice Harlan disagreed with the majority's decision to uphold a lower court ruling that allowed a mortgage company to foreclose on property even though it had already accepted payment in full from another party. He argued that this was fundamentally unfair and violated basic principles of equity and justice. He also took issue with the fact that the original owner of the property was not given an opportunity to present evidence or argue their case before foreclosure proceedings were initiated. Furthermore, he believed that allowing such practices would create dangerous precedents and potentially lead to widespread abuse by lenders who could use similar tactics to unfairly seize properties from unsuspecting homeowners.