In the case of Lewis, Trustee in Bankruptcy, v. Manufacturers National Bank of Detroit (1960), the Supreme Court was tasked with determining whether a bank could retain funds that had been deposited by a bankrupt company prior to its bankruptcy declaration. The bankrupt company's trustee argued that these deposits were preferential transfers and should be returned to the estate for distribution among all creditors. However, the bank contended it was entitled to keep them as they were set-offs against loans made by it to the debtor before bankruptcy proceedings began. The court ruled in favor of Manufacturers National Bank stating that under Section 68(a) of the Bankruptcy Act, banks are allowed to offset mutual debts existing at time when bankruptcy is filed; thus permitting them to hold onto such deposits. This decision clarified how debt offsets work within bankruptcy law and established precedent for future cases involving similar circumstances.

In the dissenting opinion for Lewis v. Manufacturers National Bank of Detroit, Justice Brennan disagreed with the majority's interpretation of Section 60(a) of the Bankruptcy Act. He argued that this section should not be interpreted to mean that a trustee in bankruptcy could recover payments made by an insolvent debtor within four months prior to filing for bankruptcy if those payments were made while insolvent and preferred one creditor over others. Instead, he believed that such recovery should only occur if it can be proven that these preferential payments resulted in a depletion of assets available to other creditors at the time they were made - something which was not demonstrated in this case according to him. Furthermore, he contended that interpreting Section 60(a) as allowing trustees to recover all preferential transfers without proving harm would lead banks and other lending institutions into unnecessary litigation and potential loss every time they accept payment from customers who later declare bankruptcy.