In the case of Maggio v. Zeitz, Trustee in Bankruptcy (1947), the U.S Supreme Court ruled on issues related to bankruptcy law and contempt of court. The petitioner, Maggio, was a bankrupt businessman who had been held in civil contempt for failing to comply with an order to turn over his business records and assets to the trustee overseeing his bankruptcy proceedings. He argued that he could not comply because he no longer possessed these items due to theft or loss. The Supreme Court held that a person cannot be indefinitely jailed for civil contempt if they are genuinely unable to comply with a court's turnover order; however, it is up them (the contemnor)  to prove their inability beyond just mere assertions. Furthermore, the burden remains on them until they have produced everything within their power and control.

In the dissenting opinion for Maggio v. Zeitz, Justice Frank Murphy argued that the majority's decision undermined the power of bankruptcy courts to enforce their orders and protect assets from fraudulent concealment or disposal. He contended that a bankrupt individual who refuses to comply with court orders should not be able to escape punishment simply by claiming they no longer possess those assets. In his view, such an approach would incentivize dishonesty and obstruct justice in bankruptcy proceedings. Furthermore, he disagreed with the majority's interpretation of 'turnover' as requiring immediate possession; instead, he believed it could also refer to past possessions which were improperly disposed of or concealed. Thus, he felt that sanctions should still apply even if a debtor claims they no longer have control over certain assets.