In the Dillman v. Hastings case of 1891, the U.S Supreme Court was tasked with determining whether a state law that allowed for tax collection on personal property located outside of its jurisdiction was constitutional. The plaintiff, Dillman, argued that his personal property in Illinois should not be taxed by Nebraska where he resided because it violated the Due Process Clause of the Fourteenth Amendment. However, the court ruled against him stating that as long as a person benefited from being within a particular jurisdiction (in this case Nebraska), they were subject to taxation even if their properties were out-of-state. Therefore, according to this ruling, states could constitutionally impose taxes on residents' income earned or assets held elsewhere.

In the dissenting opinion for Dillman v. Hastings, Justice Lamar disagreed with the majority's interpretation of a Michigan law regarding property rights. He argued that under this law, when a married woman sold her land, her husband did not need to sign off on it if he had previously given his consent in writing. The majority held that such written consent was insufficient and required an additional signature at the time of sale; however, Justice Lamar contended that this requirement was unnecessary and inconsistent with the intent of Michigan lawmakers who sought to empower women by giving them greater control over their property. Furthermore, he believed that requiring an additional signature would create undue hardship for women trying to sell their properties independently.