In the 1987 case of Tulsa Professional Collection Services, Inc. v. Joanne Pope, the U.S Supreme Court ruled on whether a creditor's claim against an estate must be filed within a certain time period to be valid under Oklahoma law and if this violated the Due Process Clause of the Fourteenth Amendment. The court held that creditors are entitled to notice by mail or other means as certain to ensure actual notice when their claims are known or reasonably ascertainable by an executor/administrator of an estate. However, it also stated that if a creditor could not have been reasonably identified and located by said executor/administrator then posting in newspapers would suffice for notification purposes. This ruling was significant because it clarified how executors should handle notifying potential unknown creditors about probate proceedings while balancing due process rights for those creditors whose identities were known or easily discoverable.

The dissenting opinion in the case of Tulsa Professional Collection Services, Inc. v. Joanne Pope argued that the majority's interpretation of Section 1982(a) was overly broad and not supported by its legislative history or purpose. The dissent contended that Congress intended this provision to apply only to claims against an estate itself, rather than those made against individual beneficiaries or executors. It further asserted that extending the statute's reach would unnecessarily complicate probate proceedings and potentially harm innocent third parties who had no knowledge of a debt claim until after it expired under state law. Additionally, they disagreed with the majority’s view on nonclaim statutes as being inconsistent with federal bankruptcy laws; instead arguing these statutes serve important purposes such as providing finality for estates and protecting timely creditors from late-coming claims.