In the case of State National Bank of Springfield v. Dodge, the Supreme Court was asked to decide whether a state bank could sue a non-resident in a state court. The plaintiff, State National Bank of Springfield, was a state bank located in Illinois. The defendant, Dodge, was a non-resident of Illinois. The bank had loaned money to Dodge, and Dodge had failed to repay the loan. The bank sued Dodge in an Illinois state court, and Dodge argued that the state court did not have jurisdiction over him because he was a non-resident. The Supreme Court held that the state court did have jurisdiction over Dodge. The Court reasoned that the state court had jurisdiction because the bank was a state bank, and the loan was made in Illinois. The Court also noted that the state court had jurisdiction over the subject matter of the dispute, which was the repayment of the loan. The Court concluded that the state court had jurisdiction over Dodge, and the bank was allowed to proceed with its lawsuit.

Justice Field delivered the dissenting opinion in State National Bank of Springfield v. Dodge, arguing that a state bank was not subject to federal taxation on its capital stock and surplus profits. He argued that Congress had no power to tax such property under the Constitution, as it was not within any of the categories enumerated by Article I, Section 8 or elsewhere in the document. Furthermore, he noted that if Congress did have such authority then it would be an unconstitutional delegation of legislative power from one branch of government to another since only states could impose taxes on their own citizens and businesses. Finally, Justice Field pointed out that even if this were a permissible exercise of congressional authority then there should at least be some reasonable basis for taxing these entities differently than other corporations which are similarly situated but do not happen to be owned by a state government.