Brent v. Maryland was a United States Supreme Court case that addressed the issue of whether a state could impose a tax on a non-resident's income from property located within the state. The case was brought by a Maryland resident, William Brent, who owned property in the state of Maryland but lived in the District of Columbia. Brent argued that the state of Maryland had no authority to impose a tax on his income from the property, as he was not a resident of the state. The Supreme Court ruled in favor of Brent, holding that the state of Maryland had no authority to impose a tax on a non-resident's income from property located within the state. The Court reasoned that the power to tax was an attribute of sovereignty, and that the state of Maryland had no authority to exercise its sovereignty over a non-resident. The Court further held that the power to tax was limited to the state in which the property was located, and that the state of Maryland had no authority to impose a tax on a non-resident's income from property located within the state. The Court's decision in Brent v. Maryland established the principle that a state cannot impose a tax on a non-resident's income from property located within the state. This principle has been applied in numerous cases since, and has been used to protect the rights of non-residents to be free from taxation by states in which they do not reside.

Justice Field delivered the dissenting opinion in Brent v. Maryland, arguing that the state of Maryland had a right to impose taxes on goods imported from other states for sale within its borders. He argued that this was an exercise of the state's police power and did not violate any provision of either the Constitution or laws passed by Congress. Furthermore, he noted that if such taxation were found to be unconstitutional, it would have far-reaching implications as many other states also imposed similar taxes on imports from out-of-state sources. Justice Field concluded his dissent by noting that while he disagreed with the majority opinion, he respected their decision and accepted it as binding precedent under stare decisis.