In Bank of Kentucky v. Adams Express Company, the Supreme Court of the United States was asked to decide whether a state bank could recover a debt from a national express company. The bank had loaned money to a customer, who then used the funds to purchase goods from the express company. The express company refused to pay the debt, claiming that it was not liable for the debt because it was a national express company and not subject to the laws of the state in which the bank was located. The Supreme Court held that the express company was liable for the debt. The Court reasoned that the express company was doing business in the state and was therefore subject to the laws of the state. The Court also noted that the express company had accepted the customer's money and had not objected to the transaction at the time. Therefore, the express company was liable for the debt and the bank was entitled to recover the money it had loaned. In conclusion, the Supreme Court held that the express company was liable for the debt and the bank was entitled to recover the money it had loaned. The Court reasoned that the express company was doing business in the state and was therefore subject to the laws of the state. The Court also noted that the express company had accepted the customer's money and had not objected to the transaction at the time.

Justice Field delivered the dissenting opinion in Bank of Kentucky v. Adams Express Company, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that a state cannot constitutionally impose taxes on interstate commerce because it would interfere with Congress' exclusive power to regulate such commerce under Article I, Section 8 of the Constitution. Furthermore, he contended that even if a tax were imposed by a state on an instrument used for interstate commerce, it could not be enforced against an out-of-state party who had no control over its use or disposition within the taxing jurisdiction. In this case specifically, Justice Field argued that since Adams Express Company did not have any control over how their drafts were used in Kentucky nor did they receive any benefit from them being there; thus they should not be subject to taxation by Kentucky as it violates both constitutional principles and common law precedent which states only those persons who are present within a taxing jurisdiction can be taxed upon property located therein.