In Lewis v. Commissioners, the Supreme Court of the United States was asked to decide whether a tax imposed by the state of Maryland on the income of a non-resident was constitutional. The plaintiff, Lewis, was a resident of Pennsylvania and had received income from a trust in Maryland. The state of Maryland had imposed a tax on the income of non-residents, which Lewis argued was unconstitutional. The Supreme Court held that the tax was constitutional. The Court reasoned that the tax was not a direct tax, and thus did not violate the Constitution. The Court also held that the tax did not violate the privileges and immunities clause of the Constitution, as the tax was imposed on all non-residents, regardless of their state of residence. The Court also held that the tax did not violate the due process clause of the Constitution, as the tax was imposed on all non-residents, regardless of their state of residence. The Court reasoned that the tax was not discriminatory, and thus did not violate the due process clause. The Court concluded that the tax was constitutional, and thus affirmed the decision of the lower court.

In Lewis v. Commissioners, the Supreme Court was asked to decide whether a tax imposed by the state of Maryland on certain railroads violated the Constitution’s Contract Clause. The majority opinion held that it did not violate this clause because there was no contract between the state and railroad companies which would be impaired by such taxation. Justice Field dissented from this decision, arguing that while there may have been no express contract between them, an implied one existed in light of prior legislation passed by both parties which granted specific rights to these railroads in exchange for their agreement to pay taxes as prescribed therein. He argued that any subsequent change or impairment of those rights through taxation constituted a violation of this implied contractual arrangement and thus should be found unconstitutional under the Contract Clause.