In the case of Sioux City Terminal Railroad and Warehouse Company v. Trust Company of North America, 1898, the U.S Supreme Court was tasked with determining whether a foreclosure sale could be set aside due to inadequate price or unfairness in proceedings. The Trust Company of North America held a mortgage on property owned by Sioux City Terminal Railroad and Warehouse Co., which defaulted on its payments leading to a foreclosure sale where the trust company purchased it for significantly less than its value. The railroad company argued that this constituted an unfair advantage and sought to have the sale invalidated. The court ruled against setting aside such sales unless there were clear indications of fraud, mistake or surprise affecting parties' rights at stake; mere inadequacy in price would not suffice as grounds for invalidation unless it was so gross as to shock one's conscience or imply fraud itself. Furthermore, no evidence suggested any irregularity during proceedings nor did they find any misconduct from trust company’s part while purchasing said property at auction. This ruling underscored courts’ reluctance towards interfering with completed sales under regular judicial procedures except when fairness principles are seriously compromised.

The dissenting opinion in the case of Sioux City Terminal Railroad and Warehouse Company v. Trust Company of North America argued that the majority's decision was inconsistent with previous rulings regarding railroad receiverships. The dissenters believed that a receiver should not be appointed for a solvent corporation unless it is necessary to preserve its assets or if there are other compelling reasons, which they did not believe were present in this case. They also disagreed with the majority's interpretation of Iowa law, arguing that it does not allow for such broad use of receivership as a remedy. Furthermore, they contended that even if state law allowed for such an action, federal courts should exercise restraint when considering whether to appoint a receiver due to potential negative impacts on commerce and industry.