The First National Bank in Plant City v. Dickinson case of 1969 revolved around the issue of whether Florida's tax scheme, which taxed national banks more heavily than other financial institutions, was discriminatory and violated federal law. The Supreme Court ruled that it did indeed violate the Federal Fourteenth Amendment’s Equal Protection Clause. This decision was based on a comparison between taxes imposed on national banks and those levied against similarly situated businesses within Florida - primarily state-chartered savings and loan associations (S&Ls). The court found that S&Ls were given preferential treatment under Florida's tax laws compared to national banks, thus creating an unfair disparity. Therefore, this ruling affirmed that states cannot discriminate against national banking associations through their taxation schemes.

In the dissenting opinion for First National Bank in Plant City v. Dickinson, Comptroller of Florida et al., Justice Hugo Black disagreed with the majority's decision that a state could not tax a national bank more heavily than it taxed other financial institutions within its borders. He argued that this interpretation was inconsistent with previous rulings and undermined states' rights to manage their own fiscal affairs. According to him, there was no constitutional or statutory provision preventing states from imposing higher taxes on national banks compared to local ones if they so chose. Furthermore, he contended that such differential taxation did not necessarily discriminate against national banks but simply reflected different policy considerations at the state level.