United States v. McBratney was a United States Supreme Court case that dealt with the issue of whether a federal court had jurisdiction to hear a case involving a dispute between two citizens of the same state. The dispute in question was over a contract for the sale of land in Arkansas. The Supreme Court held that the federal court did not have jurisdiction to hear the case, as the dispute was between two citizens of the same state and did not involve any federal question. The case arose when the plaintiff, McBratney, sued the defendant, the United States, in the Circuit Court of the United States for the Eastern District of Arkansas. McBratney alleged that he had entered into a contract with the United States for the sale of certain land in Arkansas. The United States denied the allegations and argued that the Circuit Court did not have jurisdiction to hear the case, as the dispute was between two citizens of the same state and did not involve any federal question. The Supreme Court agreed with the United States and held that the Circuit Court did not have jurisdiction to hear the case. The Court reasoned that the dispute was between two citizens of the same state and did not involve any federal question. The Court further noted that the Constitution does not grant the federal courts jurisdiction over disputes between citizens of the same state. Therefore, the Supreme Court held that the Circuit Court did not have jurisdiction to hear the case.

Justice Field delivered the dissenting opinion in United States v. McBratney, arguing that the majority's decision was contrary to both precedent and common sense. He argued that a tax imposed on an individual for their own benefit should not be considered a "tax" under the Constitution, as it is not intended to raise revenue or fund public services. Furthermore, he noted that if such taxes were allowed then Congress would have virtually unlimited power over individuals' lives and property without any constitutional limitation whatsoever. Justice Field concluded by stating his belief that allowing this type of taxation would lead to tyranny and oppression of citizens by government officials who are given too much discretion with no accountability or oversight from other branches of government.