In United States v. State Bank, the United States Supreme Court addressed the issue of whether the federal government had the power to tax state banks. The Court held that the federal government did have the power to tax state banks, as long as the tax was not so onerous as to interfere with the state's ability to regulate the banks. The case arose when the United States imposed a tax on the State Bank of Mississippi. The bank argued that the tax was unconstitutional because it interfered with the state's power to regulate its own banks. The Supreme Court disagreed, holding that the federal government had the power to tax state banks, as long as the tax was not so onerous as to interfere with the state's ability to regulate the banks. The Court reasoned that the power to tax was an inherent power of the federal government, and that the power to tax was necessary to support the government's other powers. The Court also noted that the tax imposed on the State Bank of Mississippi was not so onerous as to interfere with the state's ability to regulate its own banks. In conclusion, the Supreme Court held that the federal government had the power to tax state banks, as long as the tax was not so onerous as to interfere with the state's ability to regulate the banks. The Court's decision established an important precedent for the federal government's power to tax state banks.

In United States v. State Bank, the Supreme Court was tasked with determining whether a state bank could be sued in federal court for failing to pay taxes owed to the United States government. The majority opinion held that such suits were permissible under existing law and precedent. However, Justice Field dissented from this ruling on two grounds: first, he argued that Congress had not given explicit authority for such suits; second, he maintained that allowing states to be sued by the federal government would violate principles of sovereign immunity established in prior cases. He concluded his dissent by noting that if Congress wished to allow these types of actions against states it should pass legislation explicitly authorizing them rather than relying on judicial interpretation of existing laws and precedents.