In the case of Norwest Bank Worthington, et al. v. James R. Ahlers et ux., 1987, the U.S Supreme Court had to decide whether a debtor's promise to contribute his labor and expertise in farming operations could be considered as "new value" under Chapter 11 bankruptcy reorganization plan. The court held that such a contribution did not constitute new value because it was neither money nor money's worth; therefore, it didn't meet the requirements set out by Section 1129(b)(2)(B)(ii) of the Bankruptcy Code for granting junior interests on senior claims in violation of absolute priority rule (APR). This decision clarified that only tangible financial contributions can qualify as new value capable of justifying an exception to APR under Chapter 11 bankruptcy proceedings.

In the dissenting opinion for Norwest Bank Worthington, et al. v. James R. Ahlers Et Ux., Justice Blackmun disagreed with the majority's interpretation of "fair and equitable" in Section 1129(b) of the Bankruptcy Code as requiring a market interest rate on deferred cash payments to unsecured creditors in a reorganization plan proposed by insolvent debtors. He argued that such an interpretation was not supported by either legislative history or precedent, and it unnecessarily restricted bankruptcy courts' discretion to confirm plans that were fair and equitable under all circumstances of each case. Furthermore, he contended that this decision would make it more difficult for family farmers facing financial distress to successfully reorganize their debts under Chapter 11 because they often lacked access to new capital at market rates due to their insolvency status.