In County of Scotland v. Thomas, the Supreme Court of the United States was asked to decide whether a county in Scotland could sue a citizen of the United States in a United States court. The county had obtained a judgment against the citizen in a Scottish court, but the citizen had not paid the judgment. The county then sought to enforce the judgment in a United States court. The Supreme Court held that the county could not sue the citizen in a United States court. The Court reasoned that the United States had no jurisdiction over the citizen, and that the county was not a citizen of the United States and thus could not sue in a United States court. The Court also noted that the United States had no treaty with Scotland that would allow the county to sue in a United States court. The Court concluded that the county could not sue the citizen in a United States court, and that the judgment of the Scottish court could not be enforced in a United States court. The Court held that the county must seek to enforce the judgment in a Scottish court.

Justice Field delivered the dissenting opinion in County of Scotland v. Thomas, arguing that the majority's decision was contrary to established precedent and would have a detrimental effect on state governments' ability to collect taxes from non-residents. He argued that while it is true that states cannot tax citizens of other states without their consent, this does not mean they are prohibited from collecting taxes due them by those who reside within their borders but own property elsewhere. The Court had previously held in numerous cases that such taxation was permissible under the Constitution as long as it did not conflict with any federal law or treaty. In this case, Justice Field believed there were no such conflicts and thus concluded that Scotland County should be allowed to collect its taxes from Thomas despite his residence outside of its jurisdiction.