The United States Supreme Court case, United States v. Kimbell Foods, Inc., et al., dealt with the issue of whether federal law should create a uniform rule to determine priority in competing liens on a debtor's property or if state laws should apply. The court held that absent a significant conflict between federal interests and state law, there was no need for federal common law to override state rules regarding lien priorities. In this case, the U.S Small Business Administration (SBA) and Farmers Home Administration (FmHA) had made loans secured by personal property which were later claimed by private lenders who also had security interests in the same properties under local commercial codes. The SBA and FmHA argued their liens took precedence because they were backed by Federal Government while private lenders contended that their claims came first as per local laws since they perfected them before government agencies filed notice of theirs.

In the dissenting opinion for United States v. Kimbell Foods, Inc., Justice Rehnquist disagreed with the majority's decision to apply federal common law instead of state law in determining priority between private liens and federal tax liens arising from loans made by government agencies. He argued that there was no significant need or justification for a nationally uniform rule on this issue, as it did not involve uniquely federal interests. Furthermore, he contended that adopting such a rule would disrupt commercial relationships established under state laws and could potentially lead to unfair results due to its retroactive application. He also criticized the majority's reliance on policy considerations rather than legal principles in reaching their decision, stating that these are matters better left to Congress.