In McLeod v. Fourth National Bank of St. Louis, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue an injunction against a national bank. The case arose when the Fourth National Bank of St. Louis refused to honor a check drawn on it by McLeod, a citizen of Missouri. McLeod sued the bank in a state court, seeking an injunction to compel the bank to honor the check. The bank argued that the state court lacked jurisdiction to issue an injunction against a national bank. The Supreme Court held that the state court did have the authority to issue an injunction against a national bank. The Court reasoned that the state court had jurisdiction over the parties involved in the dispute, and that the state court had the power to issue an injunction to protect the rights of its citizens. The Court further noted that the state court had the power to issue an injunction to protect the rights of its citizens, even if the injunction was against a national bank. The Court concluded that the state court had the authority to issue an injunction against the Fourth National Bank of St. Louis, and that the injunction should be enforced. This decision established that state courts have the authority to issue injunctions against national banks, and that such injunctions should be enforced.

Justice Field delivered the dissenting opinion in McLeod v. Fourth National Bank of St. Louis, arguing that a state court had no authority to issue an injunction against a federal receiver appointed by the Circuit Court of Appeals for the Eighth Circuit. He argued that such an action was beyond its jurisdiction and violated Article III, Section 2 of the Constitution which gives exclusive jurisdiction over cases arising under federal law to courts established by Congress. Furthermore, he argued that even if it were within their power to do so, they should not have done so because it would interfere with proceedings already underway in another court and could potentially lead to conflicting judgments on similar matters between different states or districts. In conclusion Justice Field stated that while he sympathized with Mr McLeod's plight he believed this case presented a clear example where state courts must defer to those created by Congress when dealing with matters involving federal law or procedure as required by our nation’s highest legal document - The United States Constitution