In Tiffany v. National Bank of Missouri, the Supreme Court of the United States was asked to decide whether a national bank could be held liable for a breach of contract. The case arose when the National Bank of Missouri refused to honor a check drawn on it by Tiffany, a customer of the bank. Tiffany sued the bank for breach of contract, claiming that the bank had agreed to honor the check. The Supreme Court held that a national bank could be held liable for a breach of contract. The Court reasoned that a national bank was a corporation created by Congress and was subject to the same laws as any other corporation. Therefore, the bank could be held liable for a breach of contract just like any other corporation. The Court also held that the bank was not immune from liability because it was a national bank. The Court reasoned that the bank was not a governmental entity and was not immune from liability for its actions. In conclusion, the Supreme Court held that a national bank could be held liable for a breach of contract. The Court reasoned that a national bank was a corporation and was subject to the same laws as any other corporation. Therefore, the bank could be held liable for a breach of contract just like any other corporation.

Justice Field delivered the dissenting opinion in Tiffany v. National Bank of Missouri, arguing that a national bank was not liable for taxes imposed by state law on its notes and bills issued as currency. He argued that Congress had exclusive authority to regulate the issuance of such notes and bills, which could only be taxed if expressly authorized by Congress. Furthermore, he maintained that since no express authorization existed from Congress to tax these instruments issued by national banks, it would be unconstitutional for states to do so without congressional approval. Justice Field further noted that even if there were an implied power granted to states under the Constitution allowing them to impose taxes on these instruments issued by national banks, this would still conflict with other provisions of federal law governing taxation of such items; thus making any attempt at taxation invalid due to conflicting laws between different levels of government. In conclusion, Justice Field concluded his dissent stating that while he believed it was within the rights of states or municipalities to impose certain taxes upon their citizens when necessary for public purposes; however they should not have been allowed in this case because it conflicted with existing federal legislation regarding taxation powers over national banking institutions