In McClure v. Township of Oxford, the Supreme Court of the United States was asked to decide whether a township had the authority to levy a tax on the property of a non-resident. The plaintiff, McClure, was a non-resident of the township and owned property within its boundaries. The township had passed a tax ordinance that imposed a tax on all non-resident property owners. McClure argued that the ordinance was unconstitutional because it violated the Fourteenth Amendment's Equal Protection Clause. The Supreme Court held that the ordinance was constitutional. The Court reasoned that the ordinance was a valid exercise of the township's police power and that it did not violate the Equal Protection Clause. The Court noted that the ordinance was a reasonable means of raising revenue for the township and that it did not discriminate against non-residents. The Court also noted that the ordinance was not arbitrary or capricious and that it was applied equally to all non-residents. In conclusion, the Supreme Court held that the ordinance was constitutional and that the township had the authority to levy a tax on the property of a non-resident. The Court reasoned that the ordinance was a reasonable exercise of the township's police power and that it did not violate the Equal Protection Clause.

Justice Field delivered the dissenting opinion in McClure v. Township of Oxford, arguing that the majority's decision was an incorrect interpretation of Michigan law and a violation of the Fourteenth Amendment to the United States Constitution. He argued that under Michigan law, townships are not authorized to levy taxes on property within their boundaries for any purpose other than those specified by statute; thus, he concluded that since there is no statutory authority allowing township taxation for school purposes, it would be unconstitutional for such taxation to occur without legislative authorization. Furthermore, Justice Field asserted that even if such taxation were allowed under state law, it would still violate equal protection principles because it discriminates against non-residents who own land within a township but do not pay local taxes or receive benefits from them. Finally, he contended that this type of tax violates due process rights as well because landowners have no say in how their money is spent and cannot challenge its use before paying it.