In the case of Samuel T. Pulliam and Others v Edmund Christian, Assignee in Bankruptcy of William Allen, the Supreme Court was asked to determine whether a bankrupt's estate could be used to satisfy debts that were incurred prior to bankruptcy proceedings being initiated. The appellants argued that such an action would violate their rights under the Constitution as creditors who had not been paid for goods or services provided before bankruptcy proceedings began. The court ultimately ruled against them, finding that it was within the power of Congress to allow debtors' estates to be used for pre-bankruptcy debts if they so chose. This decision established precedent allowing creditors’ claims from before a debtor declared bankruptcy can still be satisfied by assets acquired during those proceedings.

In the dissenting opinion of this case, Justice McLean argued that the appellants should be allowed to recover their debt from Edmund Christian, assignee in bankruptcy of William Allen. He reasoned that since the debt was contracted prior to Allen's insolvency and before his assignment as a bankrupt, it could not be considered part of his estate and therefore should not have been assigned by him. Furthermore, he noted that while creditors are generally bound by an assignment made after insolvency has occurred, they may still sue for debts due them which were contracted before such assignment took place. Therefore, Justice McLean concluded that Pulliam et al had a right to pursue their claim against Christian despite being barred from doing so under existing law at the time.