In the 1921 case of Schaff, as Receiver of the Missouri, Kansas & Texas Railway Company v. J.C. Famecohn Company, the U.S Supreme Court was tasked with determining whether a railway company could be held liable for damages to goods transported under a bill of lading that limited liability unless claims were made within nine months after delivery or in cases where delivery never occurred. The lower court had ruled in favor of J.C. Famecohn Company and against Schaff who represented the railway company as receiver. However, upon review by the Supreme Court it was found that there had been no violation on part of the carrier since they fulfilled their obligation by delivering goods at destination without any damage or loss and hence not responsible for subsequent theft from consignee's platform which happened later on due to negligence on part of consignee himself who failed to remove them promptly from station platform despite being notified about arrival.

The dissenting opinion in the case of Schaff, as Receiver of the Missouri, Kansas & Texas Railway Company v. J.C. Famecohon Company argued that a receiver appointed by a federal court should not be held liable for damages caused by negligence during his tenure unless it can be proven that he acted with personal negligence or misconduct. The dissent emphasized that receivers are officers of the court and their actions are essentially those of the court itself. Therefore, holding them personally responsible would undermine their ability to perform duties on behalf of distressed entities without fear of personal liability and could potentially discourage competent individuals from accepting such appointments in future cases.