In the 1893 U.S. Supreme Court case of Horn v. Detroit Dry Dock Company, the court examined whether a state could impose taxes on personal property owned by non-residents but located within its jurisdiction. The plaintiff, Mr. Horn, was a resident of New York who owned two steamships that were docked and operated in Michigan waters for more than six months each year. The defendant, Detroit Dry Dock Company (representing the State), levied taxes on these ships as they were considered to be situated in Michigan despite their owner's out-of-state residency. Mr. Horn argued this taxation violated his constitutional rights under both Due Process and Equal Protection Clauses since he was not a resident of Michigan; however, the Supreme Court disagreed with him. The court ruled that states have authority to tax personal property within their borders regardless of where owners reside if such properties are used or employed continuously within said state for over half a year annually - even if those properties may occasionally leave and return during that period. This ruling affirmed states' power to levy taxes on non-resident-owned assets operating extensively within their jurisdictions while also clarifying how "domicile" is determined for taxation purposes.

In the dissenting opinion for Horn v. Detroit Dry Dock Company, it was argued that the majority's decision to uphold Michigan's law regarding liens on ships contradicted previous rulings by the Supreme Court. The dissenting justices believed that federal maritime law should supersede state laws in this case, as they felt it was a matter of national concern rather than a local one. They contended that allowing individual states to regulate such matters could lead to inconsistencies and confusion within the shipping industry, which operates across state lines and international borders. Furthermore, they expressed concerns about potential violations of due process rights under the Fourteenth Amendment if ship owners were subjected to differing legal standards depending on where their vessels happened to be located at any given time.