In County of Wilson v. National Bank, the Supreme Court of the United States was asked to decide whether a county could tax a national bank. The case arose when the County of Wilson, in Tennessee, attempted to levy a tax on the National Bank of Tennessee. The National Bank argued that it was exempt from taxation under the National Bank Act of 1864. The Supreme Court held that the National Bank was exempt from taxation by the County of Wilson. The Court reasoned that the National Bank Act of 1864 was a federal law, and that the federal government had exclusive authority to regulate national banks. The Court further held that the County of Wilson was not authorized to tax the National Bank, as this would be in conflict with the federal law. The Court concluded that the County of Wilson could not tax the National Bank, and that the National Bank was exempt from taxation.

Justice Field delivered the dissenting opinion in County of Wilson v. National Bank, arguing that the majority's decision was contrary to established precedent and would lead to a dangerous expansion of federal power over state governments. He argued that Congress had no authority under Article I, Section 8 of the Constitution to pass legislation allowing national banks to sue states for taxes due on their property or franchises. Furthermore, he noted that this case was similar to previous cases where it had been held that such suits were unconstitutional because they interfered with state sovereignty and violated principles of comity between states and the federal government. Justice Field concluded by stating his belief that if Congress could pass laws authorizing such suits against states then it would be able "to control all taxation within its limits," which is not an enumerated power granted by the Constitution.