In the 1909 Supreme Court case Mankin v. United States for the Use of Ludowici-Celadon Company, a dispute arose over whether or not certain materials were exempt from being seized under a mechanic's lien law. The Ludowici-Celadon Company had supplied roofing tiles to be used in constructing federal buildings and claimed they should be paid for their goods. However, contractor J.A. Mankin argued that since he was working on government property, his assets could not be seized to pay off debts owed to suppliers like Ludowici-Celadon. The court ruled in favor of Ludowici-Celadon company stating that while it is true that public works are generally immune from liens because they belong to the sovereign (government), this immunity does not extend to contractors who owe money for supplies used in those projects. Therefore, even though Mankin was working on government property when he incurred his debt with Ludowici-Celadon company, this did not protect him from having his assets seized as payment.

In the dissenting opinion for Mankin v. United States, Justice Harlan disagreed with the majority's interpretation of a statute that allowed contractors to be sued directly by subcontractors who had not been paid. He argued that this law was intended to protect subcontractors from unscrupulous contractors and should therefore be interpreted broadly in favor of those it sought to protect. The majority's narrow interpretation, he believed, undermined this purpose and left many subcontractors without recourse if they were not paid for their work. Furthermore, he contended that the court had overstepped its bounds by interpreting legislative intent rather than simply applying the letter of the law as written.