In State Bank v. United States, the Supreme Court was asked to decide whether the United States was liable for a debt owed to a state bank. The state bank had loaned money to a third party, who had defaulted on the loan. The state bank then sued the United States for the debt, claiming that the United States was liable for the debt because it had guaranteed the loan. The Supreme Court held that the United States was not liable for the debt. The Court reasoned that the United States had not expressly agreed to guarantee the loan, and that the state bank had not relied on any such guarantee when it made the loan. The Court also noted that the United States had not received any benefit from the loan, and that the state bank had not been misled by any representations made by the United States. The Court concluded that the United States was not liable for the debt, and that the state bank was not entitled to recover the money it had loaned. The Court's decision was unanimous.

Justice Field delivered the dissenting opinion in State Bank v. United States, arguing that the majority's decision was contrary to precedent and would lead to a dangerous expansion of government power. He argued that Congress had no authority under the Constitution to pass laws requiring state banks to pay taxes on their notes issued for circulation as money, since this was an exercise of police power which belonged exclusively to each individual state. Furthermore, he noted that such a law would be unconstitutional because it violated both due process and equal protection clauses by discriminating against certain states whose banking systems were different from those of other states. Finally, Justice Field pointed out that if Congress could impose taxes on state bank notes issued for circulation as money then they could also tax any other kind of property or business activity within a given state - something which he believed should not be allowed without express constitutional authorization from Congress itself.