In the case of Union Trust Company of St. Louis v. Westhus, 1912, the Supreme Court examined a dispute over land ownership in Missouri between two parties: The Union Trust Company and Mr. Westhus. The original owner had mortgaged his property to secure a loan from the trust company but later sold it to Mr.Westhus without informing him about the mortgage lien on it. When he defaulted on his payments, the trust company sought to foreclose on its mortgage and sell off the property which was now owned by an innocent purchaser (Westhus). In this context, Justice Holmes delivered majority opinion stating that under Missouri law, if someone buys real estate without knowledge of any existing liens or encumbrances against it then they are considered as 'innocent purchasers'. Therefore their rights must be protected even if there is default by previous owner who had taken out mortgage loan using same property as collateral security for repayment obligations towards lender institution like Union Trust Co., thus ruling in favor of Westhus.

The dissenting opinion in the case of Union Trust Company of St. Louis v. Westhus, 1912, argued that the majority's decision was incorrect because it failed to properly interpret Missouri law regarding garnishment proceedings. The dissenting justices believed that under Missouri law, a debtor could not be subjected to multiple garnishments for the same debt and therefore Union Trust should have been protected from additional claims once they had acknowledged their indebtedness to Westhus and agreed to pay him directly rather than through his employer. They also disagreed with the majority's interpretation of what constituted "property" under Missouri law, arguing that wages earned but not yet paid did not qualify as property subject to garnishment. Finally, they contended that even if such wages were considered property, they would still be exempt from garnishment under federal bankruptcy laws designed to protect wage earners from excessive financial hardship.