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The Supreme Court established that congressional power extends beyond the scope of the Constitution and that state governments cannot interfere with the federal government. McCulloch v. Maryland was a decision by the Supreme Court of the US in which the state of Maryland had attempted to form the second bank of the US by imposing a tax on all notes of banks not chartered in Maryland.  The court invoked the Necessary and Proper Clause of the Constitution, which allowed Federal government to pass laws not expressly provided in the Constitution's list of express powers, provided those laws are in useful.

McCulloch v. Maryland (1819) is one of the first and most important Supreme Court cases on federal power. In this case, the Supreme Court held that Congress has implied powers derived from those listed in Article I, Section 8. The “Necessary and Proper” Clause gave Congress the power to establish a national bank.