Mason v. Graham was a United States Supreme Court case that addressed the issue of whether a state could require a non-resident to pay a tax on the sale of real estate located within the state. The case was brought by a resident of the state of Georgia, who had sold a piece of real estate located in the state of Alabama. The state of Alabama had imposed a tax on the sale of the real estate, and the plaintiff argued that the tax was unconstitutional. The Supreme Court held that the tax was constitutional, and that the state of Alabama had the right to impose the tax on the sale of real estate located within its borders. The Court reasoned that the tax was a legitimate exercise of the state's power to regulate commerce within its borders, and that the tax did not violate the plaintiff's constitutional rights. The Court also noted that the tax was not discriminatory, as it applied equally to all non-residents who sold real estate located within the state. In conclusion, the Supreme Court held that the state of Alabama had the right to impose a tax on the sale of real estate located within its borders, and that the tax did not violate the plaintiff's constitutional rights.

Justice Field delivered the dissenting opinion in Mason v. Graham, arguing that the majority had failed to consider the implications of their decision on other cases and statutes. He argued that if a state could not tax property held by an individual for religious purposes, then it would be impossible for states to collect taxes from any corporation or association organized exclusively for religious purposes. Furthermore, he noted that this ruling was contrary to prior decisions which had upheld taxation of church property when used as a source of income or profit-making activity. Justice Field also pointed out that while Congress may have intended to protect churches from taxation through its legislation granting them exemption status, such protection did not extend beyond what was explicitly stated in those laws; thus, it should not be assumed without clear evidence otherwise. Finally, he expressed his concern over how this decision might affect future rulings regarding similar issues involving religion and government power.