In the case of Citizens & Southern National Bank v. Bougas, the Supreme Court ruled in favor of Citizens & Southern National Bank (C&S). The dispute arose when Demetrios Bougas filed a lawsuit against C&S in Georgia state court for alleged violations of the Truth in Lending Act. C&S attempted to have the case moved to federal court due to its status as a national bank and citing an 1882 law that stated lawsuits involving national banks should be held either where they were established or where they operated their main office. However, Bougas argued that this was not applicable since it did not explicitly mention branch offices like his local one. The Supreme Court disagreed with Bougas' interpretation and found that Congress intended for "established" to include any place where a bank is authorized to do business, including branches. Therefore, it concluded that cases could be heard wherever these branches are located rather than just at their principal places of business. This ruling allowed national banks more flexibility regarding which courts hear cases brought against them.

In the dissenting opinion for Citizens & Southern National Bank v. Bougas, Justice William H. Rehnquist argued that the majority's interpretation of Section 94 was incorrect and inconsistent with its historical context. He contended that Congress intended to protect national banks from being sued in inconvenient jurisdictions when it enacted Section 94, not just to limit where they could be sued by their customers or shareholders as suggested by the majority. The justice also criticized the court's reliance on policy considerations rather than statutory language in reaching its decision, asserting this approach undermined legal certainty and predictability. Furthermore, he expressed concern about potential negative impacts on national banking system due to increased litigation costs and administrative burdens resulting from allowing suits against national banks in places other than their designated home counties.