In the United States v. Conway case of 1899, the Supreme Court ruled on a matter involving taxation and bankruptcy. The defendant, Conway, had declared bankruptcy and his assets were being distributed among his creditors by an assignee. However, there was disagreement over whether certain taxes owed to the U.S government should be considered as debts that could be discharged in bankruptcy or if they held priority status over other claims against Conway's estate. The court decided that under Section 3466 of the Revised Statutes - which states that "in cases of insolvency" federal tax claims take precedence - did not apply to proceedings under Bankruptcy Act because it is not a case of general insolvency law but rather special proceeding for distribution of debtor's property among all its creditors including those whose debts are provable in such proceedings and those whose are not.

In the dissenting opinion for United States v. Conway, it was argued that the majority's interpretation of the law was too broad and could potentially infrive on individual rights. The dissenting justices believed that while Congress has power to regulate interstate commerce, this does not extend to criminalizing acts done within a state which may indirectly affect such commerce. They contended that if every act affecting interstate trade can be federally regulated, then there would be virtually no limit to federal jurisdiction over matters traditionally left up to states' discretion. This view held by the minority emphasized a strict constructionist approach towards interpreting Congressional powers under Commerce Clause of Constitution and warned against potential encroachments upon states’ rights and civil liberties.