The Bank of the United States brought a suit against Levi Tyler for failing to pay back a loan. The bank argued that it had given Tyler an extension on his debt, and he was still in default. However, Tyler claimed that the bank did not have legal authority to extend him credit because its charter had expired before he took out the loan. The Supreme Court ruled in favor of Tyler, finding that since Congress had allowed the original charter to expire without renewing it, any contracts made by the bank after this point were invalid and unenforceable. This decision established precedent limiting banks' ability to make loans beyond their charters’ expiration dates and clarified how states should interpret contracts with national banks whose charters have lapsed or been revoked.

In the case of The Bank of the United States v. Levi Tyler, Justice Thompson delivered a dissenting opinion in which he argued that Congress had no authority to incorporate a bank and grant it exclusive privileges. He believed that such powers were reserved for the states under the Constitution, and thus any attempt by Congress to do so was unconstitutional. Furthermore, he argued that even if Congress did have this power, they could not delegate it to another body or corporation as they had done with The Bank of the United States. In his view, allowing corporations like this one would lead to an abuse of power and create monopolies over certain industries which would be detrimental to citizens' rights and freedoms. Ultimately Justice Thompson concluded that granting special privileges or immunities from taxation was beyond Congressional authority because these are matters left up exclusively for state governments according to Article I Section 10 Clause 1of the Constitution