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The Studley v. Boylston National Bank case in 1912 revolved around a dispute between the trustee of Collver Tours Company, which had gone bankrupt, and Boylston National Bank. The bank held two checks from the company that were not paid due to insufficient funds. After bankruptcy was declared, the bank applied these checks to an existing debt owed by Collver Tours Company without notifying or getting approval from Studley, who as trustee should have been involved in any decisions regarding the assets of the bankrupt entity. The Supreme Court ruled in favor of Studley on appeal after he sued for recovery of those funds arguing that they belonged to all creditors and not just one (Boylston). The court agreed with this argument stating that once bankruptcy is declared, all assets belong collectively to all creditors and must be distributed equitably among them; no creditor has a right over others unless there's a legal preference established before insolvency.
In the dissenting opinion for Studley, Trustee in Bankruptcy of Collver Tours Company v. Boylston National Bank, Justice Holmes disagreed with the majority's ruling that a bank could not be held liable for accepting deposits from a company it knew was insolvent. He argued that if a bank knowingly accepts money from an insolvent depositor and uses it to pay off the depositor's debt to itself, then this should be considered as receiving payment while knowing about insolvency. This would make such payments recoverable by bankruptcy trustees under existing law at that time. The justice believed there was enough evidence suggesting that Boylston National Bank had knowledge of Collver Tours' financial condition when they accepted their deposit and used it to offset its overdrafts which made them liable according to him.