The U.S. Supreme Court case First National Bank in St. Louis v. State of Missouri at the Information of Barrett, Attorney General (1923) revolved around a dispute over taxation laws and their application to national banks operating within state boundaries. The First National Bank in St. Louis argued that it was unfairly taxed by the State of Missouri on its federal bonds, which were exempt from state taxes under federal law as per Section 3701, Revised Statutes of the United States (U.S.C., Title 31). However, Missouri contended that this tax was not directly imposed on these bonds but rather on bank shares owned by shareholders who are residents or citizens of the state; hence it did not violate any federal statutes. The Supreme Court ruled against the bank's claim and held that states have authority to levy taxes upon shares in national banks located within their jurisdiction without violating any constitutional provisions or infringing upon powers reserved for Congress under Article I §8 cl2 & cl17 Constitution US.

In the dissenting opinion for First National Bank in St. Louis v. State of Missouri, Justice McReynolds disagreed with the majority's view that a state could tax national banks based on their shares' value without violating federal law. He argued that this interpretation was inconsistent with previous court decisions and Congressional intent when it enacted relevant banking legislation. According to him, Congress intended to protect national banks from excessive state taxation by limiting taxes to those imposed on other moneyed capital in the hands of individual citizens within a given state. By allowing states to impose additional taxes on these institutions, he believed that they were undermining their ability to function effectively and competitively against local financial entities not subject to such levies.