In the case of Fourth National Bank of New York v. American Mills Company, 1890, the Supreme Court ruled on a dispute involving commercial paper and banking law. The American Mills Company had deposited several promissory notes with the Fourth National Bank for collection from various debtors. However, before these debts could be collected, one debtor declared bankruptcy while another failed to pay due to financial difficulties. The bank then deducted its fees from the remaining funds that were supposed to be returned to American Mills Company after collecting all debts. This led to a lawsuit by American Mills against Fourth National Bank claiming it was not liable for these charges as they were incurred due to non-payment by third parties and not because of any fault on their part. The Supreme Court held in favor of Fourth National Bank stating that under common banking practice at that time; banks were allowed deduct their fees first before returning any leftover funds back to customers when collecting debts on behalf of them even if some debtors fail or refuse payment.

The dissenting opinion in the case of Fourth National Bank of New York v. American Mills Company disagreed with the majority's interpretation of Alabama law regarding garnishment proceedings. The dissent argued that under Alabama law, a foreign corporation doing business within the state could be considered a resident for purposes of garnishment proceedings and thus, service upon its agent was sufficient to establish jurisdiction over it. They contended that this interpretation was consistent with both statutory language and prior court decisions interpreting similar statutes in other states. Furthermore, they believed that allowing such corporations to escape liability simply because they were not technically "residents" would undermine public policy by providing them an unfair advantage over domestic companies who are subject to these laws. Therefore, they concluded that the judgment against American Mills should stand.