In the case of Colvin v. Jacksonville in 1894, the U.S Supreme Court ruled on a dispute involving land ownership and tax liability. The city of Jacksonville had sold property owned by Mrs. M.A Colvin due to unpaid taxes, which was then purchased by Mr. J.J Daniel who later transferred it to his wife, Mrs. E.E Daniel. However, Mrs.Colvin claimed that she never received proper notice about her tax delinquency or the subsequent sale of her property as required under Florida law at that time. The court held that while there may have been procedural errors in notifying Mrs.Colvin about her tax liabilities and the sale of her property, these did not violate any constitutional rights because they were state procedures rather than federal ones. Furthermore, even if such violations occurred at a state level they could only be addressed through local courts within Florida itself rather than being escalated directly to the U.S Supreme Court for resolution.

In the dissenting opinion for Colvin v. Jacksonville, it was argued that the city of Jacksonville had no right to tax a federal agency such as a national bank. The dissenting justices believed that this taxation violated the Supremacy Clause of the U.S Constitution which states that federal law takes precedence over state or local laws. They contended that allowing cities to impose taxes on national banks would give them undue influence and control over these institutions, potentially undermining their ability to function effectively at a national level. Furthermore, they expressed concern about potential conflicts between different levels of government if municipalities were allowed to levy taxes against entities created and regulated by Congress.