Corson 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 Corson, who owned property in the state of Pennsylvania. Corson argued that the Maryland tax on his Pennsylvania income was unconstitutional because it violated the Due Process Clause of the Fourteenth Amendment. The Supreme Court held that the Maryland tax was constitutional. The Court reasoned that the tax was not an unreasonable burden on interstate commerce, and that it did not violate the Due Process Clause because it was applied equally to all non-residents. The Court also noted that the tax was not discriminatory, as it was applied to all non-residents regardless of their state of residence. In conclusion, the Supreme Court held that the Maryland tax on non-resident income from property located within the state was constitutional. The Court reasoned that the tax was not an unreasonable burden on interstate commerce, and that it did not violate the Due Process Clause because it was applied equally to all non-residents.

Justice Field delivered the dissenting opinion in Corson v. Maryland, arguing that the majority's decision was contrary to both precedent and common sense. He argued that a state cannot be held liable for damages caused by its officers when they are acting within their authority as agents of the state, even if those actions were illegal or unconstitutional. The Court had previously established this principle in numerous cases, including Osborn v. Bank of United States (1824), which stated that "the government is not responsible for torts committed by its officers while engaged in governmental functions." Justice Field further noted that allowing states to be sued would create an untenable situation where every act taken by a public official could potentially lead to costly litigation against the state itself. Finally, he argued that it was unjust for citizens who have suffered at the hands of their own government officials to be denied any recourse due solely to technicalities regarding sovereign immunity and other legal doctrines.