The Commercial Bank of Pennsylvania v. Armstrong case in 1892 revolved around a dispute over the payment of bonds issued by the state of Louisiana. The bank, as a bondholder, sued for payment on these bonds from Armstrong and others who were acting as agents for the state. However, they argued that they should not be held personally liable because they were merely representatives of the state and did not personally guarantee repayment. The Supreme Court ruled in favor of Armstrong and his co-defendants, stating that while states could issue bonds to raise funds, their agents could not be held personally responsible for repaying those debts unless there was clear evidence showing personal liability or misconduct on their part.

In the dissenting opinion for Commercial Bank of Pennsylvania v. Armstrong, it was argued that the majority's decision to uphold a lower court ruling in favor of Armstrong contradicted established legal principles regarding contracts and obligations. The dissenting justices believed that when an individual or entity agrees to pay a certain sum by a specific date, they are obligated to fulfill this agreement regardless of any unforeseen circumstances or difficulties. They contended that if such agreements could be easily voided due to unexpected hardships, then all contractual obligations would become uncertain and unreliable. Furthermore, they disagreed with the majority's interpretation of "impossibility," arguing instead that this term should only apply in cases where fulfilling an obligation has truly become impossible rather than merely inconvenient or difficult.