In the United States v. City of New Britain et al., 1953, the U.S. Supreme Court was tasked with determining priority between federal tax liens and local property tax liens on a bankrupt's estate in Connecticut. The court ruled that "the first in time is the first in right," meaning whichever lien was filed first takes precedence over those filed later, regardless of whether they are federal or local. This decision clarified previous confusion about how to prioritize competing claims from different levels of government on a debtor's assets, establishing an important precedent for future cases involving similar issues.

In the dissenting opinion for UNITED STATES v. CITY OF NEW BRITAIN et al., Justice Black disagreed with the majority's decision that federal tax liens took precedence over certain local property taxes. He argued that Congress intended to give priority to local government interests when it enacted the Federal Tax Lien Act of 1942, which stated that "the lien imposed by this section shall not be valid as against any mortgagee, pledgee, purchaser or judgment creditor until notice thereof has been filed." According to Justice Black, this language indicated a clear intent on behalf of Congress to protect those who had acquired rights in property before a federal tax lien was established. Therefore, he believed that state and municipal governments should also be included within these protections because they often have pre-existing claims on properties due to unpaid real estate taxes or assessments. In his view, giving priority status only to private creditors would unfairly disadvantage public entities and potentially undermine their ability to collect necessary revenue.