The Supreme Court case of Louisiana, ex rel. The New York Guaranty and Indemnity Company v. Steele was a case that dealt with the issue of whether a state could sue a foreign corporation in its own courts. The case arose when the New York Guaranty and Indemnity Company (NYGIC) sued the Steele Company in Louisiana state court. The Steele Company argued that the state court did not have jurisdiction over it because it was a foreign corporation. The Supreme Court held that the state court did have jurisdiction over the Steele Company because it had sufficient contacts with the state of Louisiana. The Court reasoned that the Steele Company had sufficient contacts with the state of Louisiana because it had done business in the state, had property in the state, and had appointed an agent in the state to accept service of process. The Court also held that the state court had jurisdiction over the Steele Company because it had consented to the jurisdiction of the state court by filing a motion to dismiss the case. The Court concluded that the state court had jurisdiction over the Steele Company and that the case could proceed in the state court.

In the dissenting opinion of Louisiana, Ex Rel. The New York Guaranty and Indemnity Company v. Steele, Justice Field argued that the majority’s decision was not supported by precedent or logic. He noted that while it is true that a state cannot be sued without its consent, this does not mean that an individual citizen can sue another state in their own court system without permission from both states involved. In addition to this point, he also argued against the majority’s interpretation of Article III Section 2 Clause 1 of the Constitution which allows for citizens to bring suits between two different states in federal courts only if they are “diversely situated” - meaning one must reside in a different state than where they are suing from. As such, Justice Field concluded his dissent by stating that since neither party resided outside of Louisiana at any time during this case and thus were not diversely situated as required under Article III Section 2 Clause 1; therefore no suit could have been brought before a federal court regardless of whether or not Louisiana had given its consent for such action to take place within its borders.