In Baldwin et al. v. Missouri, the U.S Supreme Court ruled on a case involving taxation of intangible property held outside the state by a resident of Missouri. The appellants were trustees for bonds issued by an Oregon corporation and kept in Illinois; they argued that these assets should not be subject to taxation in their home state of Missouri as it violated due process under the Fourteenth Amendment. However, the court upheld Missouri's right to tax residents on all personal property regardless of its location, stating that domicile within a state gives it jurisdiction over income from personalty wherever arising or located unless prohibited by specific constitutional limitations. This decision reinforced states' rights to levy taxes based upon residency rather than physical location of assets.

In the dissenting opinion for Baldwin et al. v. Missouri, Justice Oliver Wendell Holmes Jr., joined by Justice Louis Brandeis, argued that the state of Missouri had not violated the Fourteenth Amendment's Due Process Clause when it taxed intangible property held outside its borders by a resident. They contended that states have broad powers to tax their residents and this includes income or assets earned or located elsewhere. The majority's decision was based on an overly narrow interpretation of due process rights which could unduly limit state taxation powers in future cases. Furthermore, they disagreed with the majority’s view that taxing out-of-state bonds amounted to extraterritorial application of law; rather they saw it as a legitimate exercise of power over individuals within its jurisdiction.