In the Zeckendorf v. Steinfeld case of 1911, the U.S Supreme Court was tasked with resolving a dispute over a debt payment between two merchants in Arizona Territory. The plaintiff, Zeckendorf & Co., had sold goods to L. Zeckendorf and A.E. Steinfeld on credit but later claimed that they were not paid for their merchandise as agreed upon by both parties. In response, the defendants argued that they had already settled their debts through an offsetting transaction where they supplied goods to the plaintiffs' store in return for clearing their outstanding balance. The lower court ruled in favor of Zeckendorf & Co., prompting an appeal from Steinfeld who contended that he should be allowed to prove his claim about this offsetting agreement during trial proceedings rather than being summarily dismissed without consideration of evidence supporting his defense. Upon review, however, the Supreme Court upheld the decision made by lower courts stating there was no error committed when it refused to allow proof regarding alleged set-off transactions because such claims are generally considered irrelevant unless explicitly stipulated within original contracts or agreements between involved parties.

In the dissenting opinion for Zeckendorf v. Steinfeld, it was argued that the majority's decision failed to properly consider and apply established principles of equity. The dissenting justices believed that there were significant errors in both fact and law made by the lower courts which should have been corrected on appeal. They contended that Mr. Zeckendorf had a clear right to redeem his property under Arizona territorial laws, as he had not received proper notice of foreclosure proceedings against him - an essential requirement for such actions to be validly executed. Furthermore, they disagreed with the majority's interpretation of 'tacking', asserting instead that this legal principle did not allow Mr. Steinfeld to add his own lien onto another creditor’s older lien without giving due notice or obtaining consent from other involved parties like Mr.Zeckendorf who would be adversely affected by such action.