In the case of In re Watts and Sachs, 1902, the U.S. Supreme Court dealt with a dispute over bankruptcy proceedings. The petitioners, Watts and Sachs, were creditors who contested an order by a lower court that allowed certain property to be exempted from being used to pay off debts owed by a bankrupt party. They argued that this exemption was not in line with federal bankruptcy laws at the time. However, their appeal was dismissed on procedural grounds because they had failed to properly file it within ten days after receiving notice of the original decision as required by law. The Supreme Court upheld this dismissal stating that strict adherence to procedure is necessary for maintaining orderly administration of justice.

The dissenting opinion in the case of In re Watts and Sachs, 1902, argued that the majority's decision to deny habeas corpus relief was incorrect. The dissenters believed that the petitioners were unlawfully detained because their extradition was based on a treaty with Great Britain which they felt did not cover their alleged crimes. They contended that this interpretation of the treaty would lead to an unjust expansion of its terms beyond what had been agreed upon by both parties at its signing. Furthermore, they expressed concern about potential abuses if such broad interpretations were allowed to stand unchallenged. Therefore, they disagreed with the majority's ruling and would have granted habeas corpus relief to Watts and Sachs.