The Ohio Life Insurance and Trust Company brought a case against Henry Debolt, the Treasurer of Hamilton County. The company argued that they had paid taxes to the county in 1851 but were not given credit for it when calculating their tax bill for 1852. They sought an injunction from the court to prevent collection of any additional taxes until their payment was credited. The Supreme Court ruled in favor of Debolt, finding that he acted within his authority as treasurer by refusing to give them credit since there was no proof that they had actually paid those taxes on time or at all. This decision established precedent regarding taxation laws and how payments must be documented before being accepted by government officials.

In this case, the Ohio Life Insurance and Trust Company (plaintiff) argued that a tax imposed by Hamilton County on its property was unconstitutional. The Supreme Court disagreed with the plaintiff's argument and held that the tax was valid under state law. Justice McLean wrote a dissenting opinion in which he argued that while states have broad authority to impose taxes, they cannot do so if it violates federal constitutional rights or interferes with interstate commerce. He further noted that since there is no dispute as to whether or not this particular tax interfered with interstate commerce, then it should be deemed invalid because of its violation of due process rights guaranteed by the Fourteenth Amendment. In conclusion, Justice McLean believed that since this particular taxation scheme violated both federal constitutional rights and interfered with interstate commerce, it should be declared invalid regardless of any state laws allowing for such taxation schemes.