In Howard County v. Booneville Central National Bank, the Supreme Court of the United States was asked to decide whether a county could tax a national bank located within its boundaries. The bank argued that it was exempt from taxation under the National Bank Act of 1864. The Court held that the bank was not exempt from taxation, and that the county had the right to tax the bank. The Court reasoned that the National Bank Act of 1864 did not explicitly exempt national banks from taxation, and that the language of the Act did not suggest that Congress intended to exempt national banks from taxation. The Court further noted that the Act did not contain any language that would suggest that Congress intended to preempt state taxation of national banks. The Court concluded that the county had the right to tax the national bank, and that the bank was not exempt from taxation under the National Bank Act of 1864. The Court's decision established that national banks are subject to taxation by the states in which they are located.

Justice Field delivered the dissenting opinion in Howard County v. Booneville Central National Bank, arguing that the majority's decision was contrary to both law and justice. He argued that a county could not be held liable for taxes due on property it had no control over, as doing so would be an unconstitutional taking of private property without just compensation. Furthermore, he noted that under Missouri state law at the time of this case, counties were only responsible for collecting taxes from their own citizens; thus any tax liability should fall upon those who owned or controlled the land in question rather than on Howard County itself. Justice Field concluded by stating his belief that if Congress wanted to impose such a burden on counties they should have done so explicitly instead of leaving it up to judicial interpretation.