The Ex Parte in the Matter of Dante, Collector of the Estate of Hutchins case in 1912 involved a dispute over inheritance tax. The Supreme Court was asked to determine whether an inheritance tax could be levied on property located outside the state where the deceased resided at their time of death. In this case, Mr. Hutchins died while residing in New York and left behind properties both within and outside New York State. The executor for his estate argued that only those properties situated within New York should be subject to its inheritance tax laws. However, upon review, it was determined by Justice Oliver Wendell Holmes Jr., writing for a unanimous court, that all assets belonging to Mr. Hutchins' estate were liable for taxation under New York law regardless of their location because they were part of his total wealth at death which he had control over during life from his domicile (New York). This decision established precedent regarding jurisdictional reach concerning state-level taxes on estates with out-of-state property holdings.

The dissenting opinion in the case of Ex Parte In The Matter Of Dante, Collector Of The Estate Of Hutchins (1912) argued that the majority's decision to allow a tax collector to seize property without due process was unconstitutional. They believed that it violated the Fifth Amendment rights of citizens by not providing them with an opportunity for a hearing before their property was taken. This, they contended, undermined fundamental principles of justice and fairness enshrined in American law. Furthermore, they disagreed with the majority's interpretation of 'due process,' arguing instead that it should encompass both procedural and substantive protections against arbitrary government action. Thus, while acknowledging the need for effective taxation systems to fund public services and infrastructure, they insisted this must be balanced against individuals' constitutional rights.