In the case of Cramer v. Wilson, 1904, the United States Supreme Court dealt with a dispute over land ownership. The plaintiff, Cramer, claimed that he had purchased a piece of property from an individual who had inherited it from his father's estate. However, the defendant argued that this was not possible because according to California law at the time (where the property was located), any real estate owned by someone at their death automatically went to their spouse if they were still alive - in this case, meaning it would have gone to Wilson’s mother instead of him directly as claimed by Cramer. The court ruled in favor of Wilson and upheld California's inheritance laws stating that upon death without a will or testamentary instrument expressing otherwise; all community property goes first to surviving spouse before being passed on further down lineal descendants.

The dissenting opinion in the case of Cramer v. Wilson argued that the majority's decision to uphold a tax on inheritances was incorrect, as it violated constitutional principles. The dissenters believed that inheritance taxes were essentially direct taxes, which are prohibited by the Constitution unless apportioned among states according to their populations. They contended that an unapportioned inheritance tax was unconstitutional and should be struck down. Furthermore, they disagreed with the majority's interpretation of what constitutes a "direct" tax under constitutional law and felt this ruling could set a dangerous precedent for future taxation cases.