In William M'Elmoyle, for the Use of Isaac S. Bailey vs. John J. Cohen, Administrator of Levy Florence, the Supreme Court was asked to decide whether a creditor could sue an administrator in order to collect on a debt owed by his decedent prior to their death. The court held that creditors have no right against administrators when it comes to debts incurred before the decedent's death and that they must look solely towards assets owned by the deceased at time of death as payment for any outstanding obligations. This decision established precedent which has been followed ever since; namely that creditors cannot pursue claims against administrators or executors with regards to pre-death debts but rather must rely upon estate assets alone as repayment for such obligations

In the case of William M'Elmoyle, for the use of Isaac S. Bailey vs John J. Cohen, Administrator of Levy Florence, Chief Justice Taney delivered a dissenting opinion in which he argued that although it was true that an administrator had no right to sell property without authority from a court or other competent tribunal, this did not mean that such sales were void and could be set aside at any time by anyone who wished to do so. He argued instead that if someone purchased property from an administrator without knowledge of their lack of authority then they should still have good title to it as long as there was nothing fraudulent about the transaction itself. Furthermore, he stated that even if there had been fraud involved in the sale then those affected would need to seek redress through legal channels rather than simply setting aside the sale on their own accord.