This Supreme Court case involved Samuel H. Carpenter, Acting Executor, and Charles Wilkins Short and J. Cleves Short, Executors named and Residuary Legatees in the Will of William Short, Deceased (Plaintiffs in Error) versus The Commonwealth of Pennsylvania (Defendant). At issue was whether a state could tax legacies or bequests made by will to non-residents of that state. The Plaintiffs argued that such taxation violated the Constitution’s Contract Clause as it impaired their rights under the will to receive property from an estate located within Pennsylvania without being taxed on it. However, the Defendant countered that since no contract existed between them prior to death regarding inheritance taxes due upon distribution of assets after death; thus there was no impairment of any contractual obligation when they imposed a legacy tax on non-resident beneficiaries who received money from estates located within its borders. Ultimately, the Supreme Court ruled in favor of Plaintiff finding that taxing legacies or bequests made by wills did indeed violate one's right under contracts protected by Article I Section 10 clause 1of U.S Constitution which states “No State shall…pass any…Law impairing Contracts".

In the case of Samuel H. Carpenter, Acting Executor and Charles Wilkins Short and J. Cleves Short, Executors named and Residuary Legatees in the Will of William Short, Deceased v. The Commonwealth of Pennsylvania, Justice McLean delivered a dissenting opinion on behalf of himself and Justices Curtis and Catron. He argued that although it was true that no state can pass any law impairing the obligation or contracts made before its passage; this did not apply to laws which were passed for public purposes such as taxation or revenue collection from estates already deceased at the time they are enacted into law. In his view these laws should be considered valid even if they had some effect on existing contracts because their purpose is beneficial to society as a whole rather than just one party involved in an agreement between two parties prior to its enactment into law by a legislature body.