In National Bank v. Burkhardt, the United States Supreme Court was asked to decide whether a national bank could sue a state court judgment debtor in federal court. The case arose when the National Bank of St. Louis, Missouri, sued Burkhardt in federal court to collect on a state court judgment. Burkhardt argued that the National Bank was not a citizen of Missouri and therefore could not sue in federal court. The Supreme Court held that a national bank was a citizen of the state in which it was located and could sue in federal court. The Court reasoned that a national bank was a creature of the federal government and was therefore a citizen of the state in which it was located. The Court also noted that the National Bank Act of 1864 gave national banks the right to sue in federal court. The Court concluded that the National Bank of St. Louis was a citizen of Missouri and could sue Burkhardt in federal court. The Court held that the National Bank Act of 1864 gave national banks the right to sue in federal court and that a national bank was a citizen of the state in which it was located. The Court's decision allowed the National Bank of St. Louis to collect on its state court judgment against Burkhardt in federal court.

In National Bank v. Burkhardt, the Supreme Court was tasked with determining whether a national bank could be held liable for damages resulting from its negligence in failing to pay out funds on behalf of an individual depositor. The majority opinion found that the bank had no such liability and therefore dismissed the case. In dissent, Justice Field argued that under existing law, banks were responsible for their own negligent acts and should not be exempt from liability simply because they are organized as a corporation or chartered by Congress. He further noted that if banks were allowed to escape responsibility for their own negligence then it would create an incentive system where banks could act recklessly without fear of consequence since they would never have to face any legal repercussions for their actions. Ultimately, he concluded that allowing this type of behavior would lead to serious harm being done both to individuals who rely on these institutions and also society at large which depends upon them functioning properly in order to maintain economic stability.