In the 1926 case of Louis Pizitz Dry Goods Company, Inc. v. Yeldell, Administrator, the United States Supreme Court dealt with a dispute over an Alabama law that allowed creditors to garnish wages from debtors without providing them any notice or opportunity for a hearing before their property was seized. The plaintiff in this case was an employee whose wages were garnished by his employer to pay off debts owed to the company. He argued that this violated his due process rights under the Fourteenth Amendment because he had not been given any prior notice or chance to contest it in court. The Supreme Court ruled against him and upheld Alabama's wage garnishment law as constitutional. It reasoned that since state laws provided other ways for debtors like him to protect their interests (such as suing for wrongful seizure after-the-fact), they did not necessarily have a right under federal constitution to receive advance notice and hearing before every type of deprivation of property.

In the dissenting opinion for Louis Pizitz Dry Goods Company, Inc. v. Yeldell, it was argued that the majority's decision to uphold Alabama's wrongful death statute as constitutional under the Fourteenth Amendment was incorrect. The dissenting justices believed that this law unfairly penalized corporations by holding them liable for damages in cases of accidental death caused by their employees' negligence while exempting individuals from similar liability. They contended that this distinction between corporations and individuals violated equal protection rights guaranteed under the Constitution because it treated similarly situated entities differently without a rational basis for doing so. Furthermore, they disagreed with the majority’s interpretation of what constituted “person” within meaning of due process clause and equal protection clause; arguing instead that these clauses should be interpreted more broadly to include both natural persons and corporate entities alike.