In County of Moultrie v. Rockingham Ten-Cent Savings-Bank, the Supreme Court of the United States was asked to decide whether a county could tax a savings bank located within its boundaries. The savings bank argued that it was exempt from taxation under the laws of the state of Virginia, where it was located. The county argued that it had the right to tax the savings bank under its own laws. The Supreme Court held that the county did not have the right to tax the savings bank. The Court reasoned that the savings bank was a private corporation, and that the state of Virginia had the exclusive power to regulate and tax such corporations. The Court further held that the county could not impose a tax on the savings bank without the express authority of the state. The Court concluded that the county had no authority to tax the savings bank, and that the savings bank was exempt from taxation under the laws of the state of Virginia.

Justice Field delivered the dissenting opinion in County of Moultrie v. Rockingham Ten-Cent Savings-Bank, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that a state statute which authorized counties to issue bonds for public works projects did not grant them authority to create corporations or lend money on their own credit. The county had issued bonds with its own name printed on them, but Justice Field contended this was done without any legal authority from either the legislature or Congress and thus violated both federal and state laws. Furthermore, he argued that since there were no statutory provisions authorizing such an action by a county government, it could not be legally enforced against creditors who had loaned money based upon these bonds being valid obligations of the county itself. In conclusion, Justice Field believed that if states wanted to authorize counties to issue corporate debt they must do so through legislation rather than allowing individual counties themselves to make such decisions unilaterally without proper authorization from higher authorities first.