In Guaranty Company v. Board of Liquidation, the Supreme Court of the United States was asked to decide whether the state of Louisiana had the right to tax the property of a foreign corporation. The case involved the Guaranty Company, a foreign corporation that had been incorporated in the state of New York. The Board of Liquidation of the state of Louisiana had attempted to levy a tax on the property of the Guaranty Company, which the company argued was unconstitutional. The Supreme Court held that the state of Louisiana did not have the right to tax the property of the Guaranty Company. The Court reasoned that the Guaranty Company was a foreign corporation and, as such, was not subject to the taxing power of the state of Louisiana. The Court further held that the state of Louisiana could not tax the property of the Guaranty Company because it was not within the jurisdiction of the state. The Court's decision in this case was significant because it established that foreign corporations are not subject to the taxing power of the states in which they are incorporated. This decision has been cited in numerous subsequent cases involving the taxation of foreign corporations.

Justice Field delivered the dissenting opinion in this case. He argued that the state of Louisiana had no authority to pass a law which would impair its own contract with Guaranty Company, as it was prohibited by Article I, Section 10 of the United States Constitution. The majority's decision allowed for such impairment and Justice Field believed this violated constitutional principles. Furthermore, he argued that if states were allowed to do so then they could easily evade their obligations whenever it suited them and thus undermine public faith in contracts made between private parties and governments. In conclusion, Justice Field maintained that allowing states to impair their own contracts ran counter to established legal principles and should not be permitted under any circumstances.