In the United States v. Centennial Savings Bank FSB case of 1990, the Supreme Court was tasked with determining whether a federal tax lien or a receivership lien held priority in terms of payment following foreclosure on property owned by an insolvent bank. The Resolution Trust Corporation (RTC), acting as receiver for Centennial Savings Bank, argued that its receivership lien should take precedence over the IRS's tax liens under federal law. However, the court ruled against RTC and in favor of IRS stating that under Federal Tax Lien Act of 1966, unless specified otherwise by Congress explicitly, federal tax liens took precedence over all other claims including those made by government agencies such as RTC. This decision reinforced the supremacy clause which states that federal laws have jurisdictional authority over state laws when there is conflict between them.

In the dissenting opinion for United States v. Centennial Savings Bank FSB, Justice Scalia disagreed with the majority's interpretation of 12 U.S.C. §1821(e)(13). He argued that this provision does not allow a receiver to avoid an unrecorded agreement that is otherwise enforceable under state law. According to him, when Congress intended to give receivers such power in other sections of the same statute, it did so explicitly and clearly; hence its absence here should be noted. Furthermore, he believed that if Congress had wanted to alter traditional property rights as significantly as the Court suggests, it would have done so more directly and unmistakably than through a mere implication from statutory language about repudiation powers of receiverships. Thus, he concluded that there was no basis for overriding state laws on real estate transactions based on federal banking regulations.