District of Columbia v. Clephane was a United States Supreme Court case that addressed the issue of whether the District of Columbia had the authority to impose a tax on the transfer of real estate. The case was brought by the District of Columbia against Clephane, who had refused to pay the tax. The Supreme Court held that the District of Columbia had the authority to impose the tax. The Court reasoned that the District of Columbia was a municipal corporation, and as such, it had the power to impose taxes on its citizens. The Court further noted that the tax was not a violation of the Constitution, as it was not a direct tax, and it was not a violation of the Fifth Amendment, as it did not constitute a taking of property without just compensation. The Court also held that the tax was not an unconstitutional burden on interstate commerce, as it was not a tax on the sale of goods or services, but rather a tax on the transfer of real estate. The Court concluded that the tax was a valid exercise of the District of Columbia's power to tax its citizens.

In District of Columbia v. Clephane, the Supreme Court was tasked with determining whether a contract between two parties could be enforced when it had been made without consideration and in violation of an existing law. The majority opinion held that such contracts were unenforceable due to their lack of consideration and illegality under the statute. However, Justice Field dissented from this ruling on the grounds that there was sufficient evidence to suggest that both parties intended for the agreement to be binding despite its lack of consideration or legal authority. He argued that if one party performed their obligations as agreed upon by both sides then they should not be denied relief simply because no money exchanged hands or because it violated a law; instead, he believed courts should look at all relevant facts before deciding whether an agreement is enforceable or not. Ultimately, Justice Field's dissent failed to sway enough justices and his position did not become part of official court precedent.