The Ozan Lumber Company v. Union County National Bank of Liberty case in 1907 revolved around a dispute over the payment of promissory notes. The Ozan Lumber Company, based in Arkansas, had issued these notes to the Union County National Bank but later refused to pay them on grounds that they were procured through fraud and misrepresentation by an agent who was not legally authorized to act on behalf of the company. However, the Supreme Court ruled against Ozan Lumber Company stating that even if there was any fraudulent activity involved, it could not be used as a defense since the bank acted in good faith and without knowledge about such misconduct when accepting those notes. Furthermore, it held that under federal law (National Banking Act), national banks can sue and be sued in any state court for matters involving contracts or property rights regardless of where they are located or incorporated.

In the dissenting opinion for Ozan Lumber Company v. Union County National Bank of Liberty, Justice Harlan argued that the majority's decision was inconsistent with prior rulings and principles of equity. He contended that a bank should not be allowed to profit from its own wrongdoing by retaining interest on funds it wrongfully withheld from a depositor. In this case, he believed the bank had acted improperly in refusing to honor checks drawn against sufficient funds and therefore should not benefit from any interest earned during the period it held onto those funds without justification. Furthermore, Justice Harlan disagreed with the majority's interpretation of Arkansas law regarding banking transactions and felt they were misapplying state statutes in their ruling.