In the case of Martin, Trustee in Bankruptcy of Virgin v. Commercial National Bank of Macon, Georgia (1917), the United States Supreme Court was tasked with determining whether a bank could retain funds that had been deposited by an insolvent debtor shortly before declaring bankruptcy. The court ruled in favor of the bank, stating that it had received the deposits in good faith and without knowledge or suspicion of insolvency. Therefore, it was not required to return them to the trustee overseeing the bankrupt estate. This decision clarified how courts should handle situations where banks receive deposits from soon-to-be-bankrupt customers and established precedent for future cases involving similar circumstances.

In the dissenting opinion for Martin, Trustee in Bankruptcy of Virgin v. Commercial National Bank of Macon, Georgia (1917), Justice Holmes argued that the majority's decision was inconsistent with previous rulings and principles established by the court. He believed that a bank should not be held liable for accepting deposits from an insolvent debtor without knowledge or suspicion of their insolvency. According to him, it is unreasonable to expect banks to investigate every depositor's financial status before accepting deposits; such a requirement would disrupt normal banking operations and impose undue burdens on banks. Furthermore, he pointed out that there were no fraudulent intentions involved in this case as both parties acted in good faith during transactions. Therefore, he disagreed with the majority’s ruling which favored creditors over innocent third-party depositors who had no knowledge about any bankruptcy proceedings against their debtors.