In the United States v. Yazell case of 1965, the Supreme Court ruled in favor of a Texas woman who had taken out a Small Business Administration (SBA) loan with her husband to rebuild their business after it was destroyed by floods. When they defaulted on the loan, only Mrs. Yazell's property was seized because under Texas law at that time, married women were not legally responsible for their husbands' debts unless they specifically agreed to be so. The government argued that federal common law should override state laws and make Mrs. Yazell liable for repayment as she benefited from the loan too; however, Justice William O Douglas disagreed stating that there is no federal general common law and thus states have autonomy over domestic relations matters such as this one which are traditionally left to them.

In the dissenting opinion for United States v. Yazell, Justice Black disagreed with the majority's decision to apply Texas state law over federal common law in determining whether a wife could be held responsible for her husband's Small Business Administration (SBA) loan. He argued that this case should have been decided based on federal common law because it involved a federally funded program and not just private parties. According to him, applying state laws would lead to inconsistent results across different states which is undesirable when dealing with national programs like SBA loans. Furthermore, he believed that under federal common law principles of fairness and justice, Mrs.Yazell should not be held liable for her husband’s debt as she had no legal capacity or authority under Texas marital property laws at the time of signing the contract.