In the case of Watkins, Trustee, et al. v. Sedberry et al., 1922, the U.S Supreme Court ruled on a dispute involving land ownership and mineral rights in Tennessee. The plaintiffs were trustees for bondholders who had invested in a company that went bankrupt; they claimed title to certain lands based on deeds from this company's predecessor. The defendants argued that these deeds did not convey any interest because at the time of their execution, there was an outstanding lease to another party which included all minerals under said lands. They also contended that even if such interests were conveyed by those deeds, they would have been forfeited due to non-payment of taxes. The court held that under Tennessee law, when real estate is sold for unpaid taxes and bought by the state or county (as happened here), it does not extinguish pre-existing leases unless specifically provided otherwise - thus preserving lessees' rights over minerals beneath such property despite changes in surface ownership. Furthermore, regarding whether tax sales could extinguish other types of interests like easements or profits à prendre (the right to take something off another person’s land), it was decided these too survive tax sales unless explicitly terminated as per local laws.

In the dissenting opinion for Watkins, Trustee, et al. v. Sedberry et al., Justice McReynolds disagreed with the majority's decision to uphold a lower court ruling that allowed a creditor to seize assets from a bankrupt debtor's estate despite those assets being previously transferred in an alleged fraudulent conveyance. He argued that this interpretation of bankruptcy law was incorrect and unfair to other creditors who also had claims on the debtor’s estate. According to him, if one creditor could bypass bankruptcy proceedings by alleging fraud and seizing property directly from the debtor’s possession without proving their claim in court or sharing it with other creditors, then all creditors should be able to do so as well - which would result in chaos and undermine the purpose of having structured bankruptcy proceedings at all.