In the case of United States et al. v. Griffin et al., Receivers, 1937, the Supreme Court was asked to determine whether a federal district court had jurisdiction over a suit brought by the U.S government against receivers appointed by state courts for insolvent insurance companies. The government sought to recover taxes it claimed were owed under federal law from these companies' assets being managed by the receivers. The defendants argued that such suits could only be heard in state courts due to principles of comity and respect for states’ rights in managing their own affairs. The Supreme Court ruled unanimously that federal courts did have jurisdiction over such cases because they involved questions of federal law (i.e., tax liability). It held that while there is generally deference given to state court proceedings involving insolvency matters, this does not extend so far as preventing enforcement of valid claims arising under national laws within those proceedings when pursued by the Federal Government itself.

The dissenting opinion in the United States v. Griffin et al., Receivers case argued that the majority's decision to allow a tax lien on property under receivership was an overreach of federal power and violated principles of equity. The dissent contended that allowing such a claim would disrupt established practices, as traditionally, taxes are not considered secured claims in bankruptcy proceedings or receiverships. They also expressed concern about potential negative impacts on creditors who had legitimate claims against the property before it went into receivership, arguing these parties could be unfairly disadvantaged by this ruling. Furthermore, they disagreed with the majority’s interpretation of relevant statutes and believed there was no clear legislative intent to give tax claims priority status in these situations.