In the 1894 case Lindsay v. First National Bank of Shreveport, the U.S. Supreme Court ruled in favor of the bank, upholding its right to collect on a promissory note that had been signed by John C. Lindsay before his death. The executor of Lindsay's estate argued that because Louisiana law required all obligations to be recorded in order for them to be enforceable against heirs or executors, and since this particular debt was not recorded at the time of Lindsay's death, it should not have been enforceable against his estate. However, the court disagreed with this argument stating that federal banking laws allowed national banks like First National Bank of Shreveport to sue on unrecorded debts such as promissory notes regardless of state laws requiring recording.

The dissenting opinion in the case of Lindsay v. First National Bank of Shreveport argued that the majority's decision was not consistent with previous rulings and interpretations of law. The dissent emphasized that a bank should be held liable for its actions, particularly when it comes to honoring checks presented by customers. It contended that if a check is drawn against sufficient funds and the bank refuses to pay, then it should be responsible for any damages resulting from this refusal. This view holds banks accountable for their role as financial intermediaries and maintains trust in banking transactions. Furthermore, the dissent pointed out inconsistencies between state laws regarding negotiable instruments which could lead to confusion or misuse if left unaddressed by federal courts.