National Bank v. Graham was a United States Supreme Court case that addressed the issue of whether a national bank could sue a state court in federal court. The case arose when the National Bank of Kentucky sued the state court of Kentucky in federal court for a debt that the state court had refused to pay. The Supreme Court held that a national bank could sue a state court in federal court, as long as the bank was suing for a debt that was due to it. The Court reasoned that the Constitution gave Congress the power to create national banks, and that Congress had the power to allow national banks to sue state courts in federal court. The Court also held that the state court was not immune from suit in federal court, as the state court was not a sovereign entity. The Court's decision established that national banks could sue state courts in federal court, and that state courts were not immune from suit in federal court.

Justice Field delivered the dissenting opinion in National Bank v. Graham, arguing that the majority's decision was contrary to established precedent and would have a detrimental effect on national banks. He argued that Congress had intended for national banks to be able to sue in state courts without having their citizenship challenged, as this would allow them access to justice regardless of where they were located or incorporated. Furthermore, he noted that if such challenges were allowed then it could lead to multiple suits being brought against one bank by different states which could cause confusion and financial hardship for those involved. Finally, Justice Field concluded his dissent by noting that allowing these types of challenges would also undermine the authority of Congress over banking matters as well as its ability to regulate interstate commerce.