In the case of Arkansas Valley Land and Cattle Company v. Mann, the Supreme Court of the United States was asked to decide whether a state could impose a tax on the sale of land owned by a non-resident. The Arkansas Valley Land and Cattle Company (AVLCC) owned land in Arkansas and sold it to a non-resident, Mr. Mann. The state of Arkansas imposed a tax on the sale of the land, which AVLCC argued was unconstitutional. The Supreme Court held that the tax was constitutional, as it was a valid exercise of the state's power to tax. The Court noted that the tax was not discriminatory, as it applied equally to all non-residents, regardless of their state of residence. Furthermore, the Court held that the tax was not an unconstitutional burden on interstate commerce, as it was a legitimate exercise of the state's power to tax. In conclusion, the Supreme Court held that the state of Arkansas had the power to impose a tax on the sale of land owned by a non-resident, and that the tax was not an unconstitutional burden on interstate commerce.

In the dissenting opinion of Arkansas Valley Land and Cattle Company v. Mann, Justice Field argued that the majority’s decision was in error because it failed to consider whether or not a contract existed between the parties. He noted that while there had been an agreement between them, it was never reduced to writing and thus could not be enforced as a valid contract under state law. Furthermore, he argued that even if such an agreement did exist, its terms were too vague for any court to interpret with certainty. As such, Justice Field concluded that no enforceable contract existed between the parties and therefore they should have been allowed to pursue their respective claims in court without interference from either party's attorneys or other third-parties.