In the 1893 case of Chapman v. Handley, the United States Supreme Court dealt with a dispute over land ownership in West Virginia. The plaintiff, Chapman, claimed that he had purchased a tract of land from an individual who had inherited it as part of his father's estate. However, the defendant, Handley and others argued that they were rightful owners due to their purchase from another heir who was not included in the initial sale to Chapman because she was still a minor at that time. The lower court ruled in favor of Handley but on appeal; however, this decision was reversed by the Supreme Court which held that under West Virginia law all heirs must be accounted for when selling inherited property regardless if some are minors or not present during transaction proceedings.

In the dissenting opinion for Chapman v. Handley, Justice Brewer argued that the majority's decision to uphold a tax on an inheritance was incorrect because it violated constitutional principles of uniformity in taxation. He contended that the Constitution required all taxes to be levied equally across different types of property and individuals, and this tax unfairly targeted inheritances specifically. Furthermore, he disagreed with the majority's interpretation of "direct" versus "indirect" taxes as outlined in Article I Section 9 Clause 4 of the U.S Constitution; according to him, an inheritance tax is indeed a direct tax which must be apportioned among states based on population rather than being uniformly applied nationwide without regard for state populations or other factors. Finally, Justice Brewer expressed concern about potential abuses if such non-uniform taxation were allowed to stand unchallenged by courts.