In the case of New York County National Bank v. Massey in 1903, the United States Supreme Court ruled on a dispute involving payment obligations and bankruptcy. The bank had loaned money to Massey, who later declared bankruptcy before repaying his debt. The bank then sued for repayment from two individuals who had guaranteed Massey's loans - one of whom was also bankrupt while the other claimed he was not liable as he did not receive notice about default until after filing for bankruptcy himself. The court held that since both guarantors were notified about their liability at different times (one before and one after they filed for bankruptcy), each should be treated differently under law: the first guarantor could be pursued by creditors despite his own insolvency; however, because second guarantor received notification only after declaring bankruptcy, this obligation was discharged along with his other debts during proceedings.

In the dissenting opinion for New York County National Bank v. Massey, it was argued that the majority's decision to uphold a lower court ruling in favor of the bank was incorrect. The dissent focused on two main points: firstly, they believed that there had been an error in interpreting and applying contract law principles; secondly, they disagreed with how evidence had been evaluated during trial proceedings. They contended that certain pieces of evidence should not have been admitted due to their irrelevance or potential biasness towards one party over another. Additionally, they felt that other relevant pieces of evidence were improperly dismissed or overlooked by both the trial court and Supreme Court majority. As such, these justices held firm in their belief that justice would be better served if a new trial were ordered where all pertinent facts could be properly considered under correct legal standards.