In the case of First National Bank of Cincinnati v. Cook, the United States Supreme Court was asked to decide whether a bank could recover a debt from a third party who had received a payment from the debtor. The debtor had made a payment to the third party, who had then used the money to pay off a debt owed to the bank. The bank argued that the payment should be considered a payment to the bank, and that the third party should be liable for the debt. The Supreme Court held that the bank could not recover the debt from the third party. The Court reasoned that the payment was made to the third party, and not to the bank, and that the third party had a right to use the money as they saw fit. The Court also noted that the bank had not taken any steps to protect its interests, such as obtaining a lien on the property or obtaining a security interest in the payment. As a result, the Court held that the bank could not recover the debt from the third party.

In the case of First National Bank of Cincinnati v. Cook, the Supreme Court was tasked with deciding whether a state court had jurisdiction to hear a suit against an out-of-state bank for breach of contract. The majority opinion held that it did not have such jurisdiction, as Congress had not given any authority to states in this regard and thus it would be unconstitutional for them to do so. Justice Field dissented from this opinion, arguing that while Congress may not have explicitly granted states power over foreign banks when entering into contracts within their borders, they should still possess such authority due to their inherent sovereignty and police powers. He further argued that allowing states to exercise control over these matters is necessary in order for citizens who enter into contracts with out-of-state banks or corporations to receive justice if those entities fail in fulfilling their obligations under said agreements.