In the case of Toledo, St. Louis & Kansas City Railroad Company v. Continental Trust Company (1899), the U.S Supreme Court was tasked with determining whether a foreclosure sale could be set aside due to inadequacy of price and lack of competitive bidding. The railroad company had defaulted on its mortgage bonds held by Continental Trust, leading to a forced sale of assets at public auction where only one bid was made for significantly less than their value. The court ruled that while gross inadequacy can suggest fraud or mistake, it alone is not sufficient grounds for setting aside a judicially ordered sale if it has been properly conducted and in accordance with law - there must also be evidence showing unfairness or misconduct during the process itself such as collusion between buyer and seller or suppression of competition among bidders which did not exist here. Therefore, despite acknowledging that better notice might have attracted more bidders hence higher bids, they upheld the validity of this foreclosure sale.

In the dissenting opinion for Toledo, St. Louis & Kansas City Railroad Company v. Continental Trust Company, Justice Harlan disagreed with the majority's decision to allow a receiver appointed by a federal court in Missouri to take control of property located in Illinois without first obtaining permission from an Illinois court. He argued that this violated principles of comity and state sovereignty because it allowed federal courts to interfere with property under state jurisdiction without consent or cooperation from state authorities. Furthermore, he contended that such actions could lead to conflicts between federal and state courts if both attempted to exercise control over the same property at once. Therefore, he believed that receivers should only be able to operate within their appointing jurisdictions unless they received explicit permission from other relevant jurisdictions.