In the case of Security Trust Company v. Dent, 1902, the U.S. Supreme Court was asked to determine whether a mortgage foreclosure sale could be set aside due to an inadequate purchase price that resulted from collusion between the purchaser and other potential bidders. The plaintiff, Security Trust Company, alleged that defendant William Dent colluded with others to suppress bidding at a public auction where his property was sold following default on a mortgage held by the trust company. The court ruled in favor of Dent stating there were no grounds for setting aside such sales unless fraud or unfairness can be proven beyond reasonable doubt; it is not enough just because prices realized are less than what might have been obtained under more favorable conditions or circumstances. The court further stated that while every mortgagor has right to have his property sold for as much as it will bring in fair market competition but he cannot complain if he fails himself or does not procure someone else who will bid more than amount offered by successful bidder.

In the dissenting opinion for SECURITY TRUST COMPANY v. DENT, 1902, Justice Harlan disagreed with the majority's decision that a state law could not affect interstate commerce and therefore was unconstitutional. He argued that states should have the right to regulate their own affairs as long as they do not interfere with federal laws or rights granted by the Constitution. In this case, he believed that Michigan had every right to tax corporations operating within its borders even if those corporations were involved in interstate commerce because such taxation did not directly impede on said commerce. Furthermore, he contended that it is up to Congress - and not individual states - to determine whether a state law interferes with interstate trade or violates any other constitutional provision.