In the case of Lane & Bodley Company v. Locke in 1893, the U.S Supreme Court was tasked with determining whether a state court's decision could be reviewed by federal courts if it involved an issue of bankruptcy. The plaintiff, Lane & Bodley Co., had sold machinery to a company that later went bankrupt before paying for it. The defendant, Locke, as assignee in bankruptcy proceedings for said company claimed ownership over this machinery under Ohio law which allowed him to void any unpaid sales made within four months prior to filing for bankruptcy. The dispute arose when both parties sought control over the same property and brought their cases before different courts - one federal (plaintiff) and one state (defendant). When these two rulings conflicted each other, the matter escalated up to the Supreme Court. The Supreme Court ruled that while generally states have jurisdiction over property within their borders; however where matters of national importance such as bankruptcy are concerned - especially those involving conflicting claims from different jurisdictions - they fall under purview of federal law. Therefore, despite Ohio’s laws allowing Locke claim on assets due his role as assignee in insolvency proceedings; since this contradicted Federal Bankruptcy Law which prioritized creditors like Lane & Bodley Co., he couldn't assert rights on purchased but unpaid goods.

In the dissenting opinion for Lane & Bodley Company v. Locke, Justice Brewer argued that the majority's decision was inconsistent with previous rulings and principles of contract law. He contended that when a party agrees to sell goods in their possession, they are implicitly promising to deliver those goods free from any claims or encumbrances by third parties. In this case, he believed that Lane & Bodley had breached this implied warranty when they sold machinery subject to a chattel mortgage without informing Locke of its existence. Therefore, he thought Locke should be entitled to recover damages for breach of warranty rather than being limited to reclaiming his purchase money as decided by the majority.