In Eyster v. Gaff, 91 U.S. 521, 23 L. Ed. 403 (1875), the debtor contended that proceedings in a foreclosure suit after the appointment of an assignee in bankruptcy were void because the assignee was not made a defendant. See id. at 522. The court disagreed, finding that the assignee could have had himself substituted for the bankrupt, or made a defendant. See id. at 524. Because he did not, the court held that the state court had jurisdiction to adjudicate the rights of the parties and the judgment was not void. See Eyster, 91 U.S. at 524-25.