Birdsall et al. v. Coolidge was a United States Supreme Court case that dealt with the issue of whether a state could tax the income of a non-resident. The case involved a dispute between the state of Massachusetts and the plaintiffs, who were non-residents of the state. The plaintiffs argued that the state's taxation of their income was unconstitutional, as it violated the Due Process Clause of the Fourteenth Amendment. The Supreme Court ultimately ruled in favor of the state, holding that the taxation of non-resident income was constitutional. The Court reasoned that the taxation of non-resident income was a legitimate exercise of the state's power to tax, and that the Due Process Clause did not prohibit such taxation. The Court also noted that the taxation of non-resident income was necessary to ensure that the state could raise sufficient revenue to fund its operations. As such, the Court held that the taxation of non-resident income was constitutional.

In the case of Birdsall et al. v. Coolidge, the Supreme Court was asked to determine whether a state court had jurisdiction over an action brought by non-residents against a resident defendant in relation to land located within that state's borders. The majority opinion held that such jurisdiction did exist and affirmed the judgment of the lower court; however, Justice Field dissented from this decision on two grounds: firstly, he argued that there was no evidence presented at trial which established any connection between either party and the State of New York; secondly, he contended that even if it could be proven that one or both parties were connected with New York in some way, then due process would require them to have been served notice before being subjected to suit in its courts. He concluded by stating his belief that allowing states to exercise jurisdiction over out-of-state litigants without providing proper notice violated their constitutional rights under Article IV Section 2 Clause 1 (the Privileges and Immunities Clause).