In the 1891 case Hoyt v. Horne, the U.S. Supreme Court dealt with a dispute over property rights and inheritance laws in Washington D.C. The plaintiff, Mrs. Hoyt, was the widow of Mr. Horne who had left his entire estate to her upon his death without any specific bequests or legacies mentioned in his will except for debts owed by him at the time of his death which were to be paid out from this estate before distribution to Mrs.Hoyt as per District law then applicable on such matters. However, after Mr.Horne's death it was discovered that he had made several loans during his lifetime secured by deeds of trust on real estate properties owned by him but these transactions weren't recorded until after Mr.Horne's demise leading to claims against these properties being filed posthumously. The court ruled that since these deeds were not properly recorded while Mr.Horne was alive they could not affect Mrs.Hoyt’s right as an heir under intestacy rules nor did they create any valid liens against her inherited property because she took possession immediately upon her husband’s death thus making all subsequent recordings ineffective against her claim.

The dissenting opinion in the case of Hoyt v. Horne argued that the majority's decision was inconsistent with previous rulings and principles of equity. The dissent contended that a creditor should not be allowed to seize property from a debtor who had already declared bankruptcy, especially when other creditors were also owed money by the same debtor. This would unfairly privilege one creditor over others and violate the principle of equal treatment for all creditors in bankruptcy cases. Furthermore, it was pointed out that allowing such seizures could potentially encourage fraudulent behavior by debtors seeking to favor certain creditors over others. Therefore, according to this view, once a debtor has filed for bankruptcy protection, all their assets should be considered part of their estate and distributed among their creditors under supervision of court-appointed trustees or receivers.