In the 1924 case of Sowell v. Federal Reserve Bank of Dallas, Texas, plaintiff J.W. Sowell sued the Federal Reserve Bank of Dallas for allegedly violating his rights under the Fourteenth Amendment by refusing to accept his gold certificates as legal tender for payment on a loan he had taken out with them. The Supreme Court ruled in favor of the bank, stating that it was within its rights to refuse gold certificates as they were not considered legal tender at that time due to an act passed by Congress during World War I which suspended their convertibility into gold or other coinage. This decision upheld Congressional power over monetary policy and confirmed that private contracts could not supersede federal law regarding what constitutes acceptable forms of payment.

The dissenting opinion in the case of Sowell v. Federal Reserve Bank of Dallas, Texas argued that the majority's decision to dismiss Mr. Sowell's claim was incorrect because it failed to consider important aspects of his employment contract with the bank. The dissenting justices believed that there were ambiguities in the terms and conditions of this contract which should have been interpreted more favorably towards Mr. Sowell as he was not involved in drafting them. They also disagreed with the majority's interpretation of certain provisions within federal banking laws, arguing these should be read as providing additional protections for employees like Mr. Sowell rather than limiting their rights or remedies under state law contracts claims against a federal reserve bank employer.