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National Bank v. Whitney 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 New York sued the state court of New York in federal court for a debt owed by the state court. The Supreme Court held that a national bank could sue a state court in federal court, as long as the debt was related to the bank's business. The Court reasoned that the Constitution gave Congress the power to create national banks, and that the power to sue in federal court was necessary to protect the interests of the bank. 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 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. Whitney, arguing that a national bank was not authorized to purchase real estate with its funds and hold it as an investment. He argued that Congress had only granted banks the power to buy and sell stocks, bonds, notes of other corporations or individuals, gold and silver bullion or coins; there was no mention of buying land for investment purposes. Furthermore, he noted that if such authority were implied from Congress’s grant of powers to national banks then they would be able to acquire large tracts of land which could lead them into competition with private citizens who are legally entitled to own property. Justice Field concluded by stating his belief that allowing this type of action would go against public policy since it is contrary both “to sound principles governing banking associations” and “the general welfare."