In Louisiana Bank v. Whitney, the Supreme Court of the United States was asked to decide whether a bank could recover a debt from a third party who had received a payment from the debtor. The bank had loaned money to a debtor, and the debtor had made a payment to a third party. The bank then sued the third party to recover the debt. The Supreme Court held that the bank could not recover the debt from the third party, because the payment had been made in good faith and the third party had no knowledge of the debt. The Court reasoned that the third party had no obligation to investigate the debtor's financial situation before accepting the payment, and that the bank should have taken steps to protect itself from the debtor's insolvency. The Court also noted that the bank had not taken any steps to secure the debt, such as obtaining a lien on the debtor's property. The Court concluded that the bank could not recover the debt from the third party, and that the third party was entitled to keep the payment.

Justice Field delivered the dissenting opinion in Louisiana Bank v. Whitney, arguing that the majority's decision was contrary to established precedent and would create a dangerous legal precedent. He argued that under existing law, when a bank holds an account for two or more persons jointly, each person is liable for all of the debts incurred by any one of them on behalf of all parties involved. In this case, he argued that since Whitney had opened an account with his son-in-law at the bank in question and both were listed as joint owners on it, they should be held equally responsible for its debts regardless of who actually made withdrawals from it. Furthermore, Justice Field noted that if only one party could be held accountable then banks would have no incentive to ensure proper authorization before allowing withdrawals from joint accounts; thus creating potential financial risks for customers who use such accounts.