Hall v. Wisconsin was a United States Supreme Court case that dealt with the issue of whether a state could impose a tax on a non-resident's income from real estate located within the state. The case was brought by a Wisconsin resident, Hall, who owned real estate in Wisconsin but lived in Illinois. Hall argued that the tax imposed by Wisconsin was unconstitutional because it violated the privileges and immunities clause of the Fourteenth Amendment. The Supreme Court held that the tax was constitutional, finding that the tax did not violate the privileges and immunities clause because it was a tax on property, not on the person. The Court reasoned that the tax was not discriminatory because it applied equally to all non-residents, regardless of their state of residence. Furthermore, the Court found that the tax was not an undue burden on interstate commerce because it was a tax on property, not on the person. In conclusion, the Supreme Court held that the tax imposed by Wisconsin on Hall's real estate was constitutional and did not violate the privileges and immunities clause of the Fourteenth Amendment. The Court found that the tax was not discriminatory and did not impose an undue burden on interstate commerce.

Justice Field delivered the dissenting opinion in Hall v. Wisconsin, arguing that the state of Wisconsin had no authority to tax a non-resident's income from real estate located within its borders. He argued that this was an unconstitutional violation of the privileges and immunities clause of Article IV, Section 2, which states that "the citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States." Justice Field further argued that such taxation would create an unequal burden on non-residents who own property within a particular state but do not reside there; they are unable to take advantage of any benefits or services provided by their home state while still being subject to taxation for owning property outside it. This creates an unfair situation where those with similar incomes may pay different amounts depending on whether they live inside or outside a certain jurisdiction. As such, he concluded that taxing non-residents' income from real estate located within another state is unconstitutional under Article IV, Section 2.