This case was brought before the United States Supreme Court by the plaintiff, The United States, against defendant The Bank of the Metropolis. At issue in this case was whether or not a state bank could be held liable for taxes on its capital stock under federal law. Specifically, it had to do with an act passed by Congress which imposed a tax on all banks and banking associations that were created after 1833. The Bank of the Metropolis argued that they should not have to pay such taxes because their charter predated 1833 and thus did not fall within the scope of this particular act. However, upon review of both parties’ arguments, including those from amici curiae briefs submitted by several states in support of either side's position, it became clear that while there may have been some ambiguity as to how far back these laws applied retroactively; ultimately Congress had intended them to apply even if a bank’s charter pre-dated 1833 since they would still benefit from any subsequent acts passed thereafter regarding taxation or other matters related thereto. As such, it was determined that The Bank of the Metropolis must comply with said federal law and pay applicable taxes due on its capital stock accordingly

In this case, the United States argued that a bank had wrongfully refused to pay taxes on its capital stock. The Supreme Court disagreed and held that the tax was unconstitutional because it violated Article I of the Constitution which states that Congress has no power to impose direct taxes without apportionment among the several states according to their respective numbers. This decision was based on an earlier ruling in Hylton v. US (1796) which found a similar tax unconstitutional as well. In his dissenting opinion, Justice Story argued that while he agreed with Hylton's holding, he believed there were significant differences between this case and Hylton such as how much money each party would have paid under either law and whether or not they could be considered "direct" taxes at all. He concluded by stating that even if these issues did not matter, then Congress still had authority over taxation matters since it is explicitly stated in Article I of the Constitution.