In Youngstown Bank v. Hughes, the Supreme Court of the United States was asked to determine whether a state court had the authority to issue an injunction against a national bank. The case arose when the Youngstown Bank and Trust Company, a national bank, refused to pay a judgment against it in favor of Hughes. Hughes then sought an injunction from the state court to prevent the bank from transferring its assets until the judgment was paid. The bank argued that the state court did not have the authority to issue such an injunction because it was a national bank and was therefore subject to the exclusive jurisdiction of the federal government. The Supreme Court held that the state court did not have the authority to issue the injunction. The Court reasoned that the federal government had exclusive jurisdiction over national banks and that the state court could not interfere with the bank's operations. The Court also noted that the federal government had the power to regulate national banks and that the state court could not interfere with this power. The Court's decision in Youngstown Bank v. Hughes established that state courts do not have the authority to issue injunctions against national banks. This decision has been cited in numerous cases since then and has been used to support the principle that the federal government has exclusive jurisdiction over national banks.

Justice Field delivered the dissenting opinion in Youngstown Bank v. Hughes, arguing that the majority's decision was contrary to established precedent and would lead to an unjust result. He argued that a bank has no right of action against its customer for failing to pay a note unless it is specifically provided by statute or contract between the parties. In this case, there was neither; thus, he concluded that the bank had no cause of action against Hughes for nonpayment of his notes. Furthermore, Justice Field noted that even if such a cause of action existed at common law prior to 1872 when Ohio adopted its current code on banking laws, it would have been abolished by virtue of Section 881 which provides "no suit shall be maintained" against any person who fails to pay their notes without statutory authority or contractual agreement between them and their creditor. Therefore, Justice Field concluded that since there was neither statutory nor contractual authority allowing Youngstown Bank's claim against Hughes for nonpayment of his notes then they were not entitled to recover from him under existing law and should not be allowed relief through judicial interpretation as proposed by the majority opinion.