In the case of Plant Investment Company v. Jacksonville, Tampa and Key West Railway Company (1893), the U.S Supreme Court was tasked with determining whether a mortgage on a railroad company's property could be foreclosed upon by bondholders when that company had defaulted on its payments. The railway company argued that it should not have to forfeit its property because it was providing an essential public service. However, the court ruled in favor of Plant Investment Company, stating that despite being used for public benefit, the railway's properties were still subject to foreclosure like any other mortgaged property if they failed to meet their financial obligations. This decision upheld creditors' rights over considerations of public utility in cases where companies default on their debts.

In the dissenting opinion for Plant Investment Company v. Jacksonville, Tampa and Key West Railway Company, it was argued that the majority's decision to uphold a Florida law allowing state courts to appoint receivers for insolvent corporations violated constitutional protections of interstate commerce. The dissent contended that this ruling effectively allowed states to interfere with and control companies engaged in interstate business operations. They believed such interference could potentially disrupt or halt these businesses entirely, which would be detrimental not only to the companies themselves but also their creditors and shareholders who reside outside of Florida. Furthermore, they asserted that federal courts should have jurisdiction over cases involving insolvent corporations conducting interstate commerce due to its national implications rather than leaving them under state court authority.