In National Bank of Commerce of Boston v. Merchants' National Bank of Memphis, the Supreme Court was asked to decide whether a national bank could sue another national bank in a federal court. The plaintiff, National Bank of Commerce of Boston, had loaned money to a third party, and the defendant, Merchants' National Bank of Memphis, had accepted the third party's promissory note as collateral. The plaintiff argued that it had the right to sue the defendant in a federal court because the defendant was a national bank. The Supreme Court held that a national bank could sue another national bank in a federal court. The Court reasoned that the National Bank Act of 1864 gave national banks the right to sue each other in federal court. The Court also noted that the defendant had accepted the third party's promissory note as collateral, and that the plaintiff had the right to sue the defendant for the money it was owed. In conclusion, the Supreme Court held that a national bank could sue another national bank in a federal court. The Court reasoned that the National Bank Act of 1864 gave national banks the right to sue each other in federal court, and that the defendant had accepted the third party's promissory note as collateral. The Court also noted that the plaintiff had the right to sue the defendant for the money it was owed.

In National Bank of Commerce of Boston v. Merchants' National Bank of Memphis, the Supreme Court was asked to decide whether a national bank could be sued in another state for an alleged breach of contract. The majority held that it could not, as Congress had only granted such banks the right to sue and be sued in their home states. Justice Field dissented from this opinion on two grounds: firstly, he argued that there was no clear language in the relevant statutes which prohibited suits against a national bank outside its home state; secondly, he noted that if Congress had intended such a prohibition they would have made it explicit rather than leaving it open to interpretation by courts. He concluded by arguing that allowing suit against national banks outside their home states would benefit both creditors and debtors alike since creditors should not be denied access to justice due solely to geographical location or technicalities related thereto.