In McComb, Executor v. Commissioners of Knox County, Ohio, the Supreme Court of the United States was asked to decide whether a tax imposed by the state of Ohio on the estate of a deceased person was constitutional. The executor of the estate argued that the tax was unconstitutional because it violated the Due Process Clause of the Fourteenth Amendment. The Court held that the tax was constitutional because it was a valid exercise of the state's power to tax. The Court noted that the tax was not arbitrary or capricious, and that it was applied uniformly to all estates in the state. The Court also noted that the tax was not excessive or oppressive, and that it was not a taking of property without due process of law. The Court concluded that the tax was a valid exercise of the state's power to tax, and that it did not violate the Due Process Clause of the Fourteenth Amendment.

In McComb, Executor v. Commissioners of Knox County, Ohio the Supreme Court was tasked with determining whether a tax imposed by the county on real estate owned by an executor and held in trust for his testator's children was valid or not. The majority opinion found that it was valid as long as it did not interfere with any federal laws or rights granted to citizens under the Constitution. However, Justice Field dissented from this decision arguing that such a tax could be considered unconstitutional if it interfered with any right given to citizens under either state law or federal law. He argued further that since there were no specific provisions within either state nor federal statutes which prohibited such taxation then there should be no interference whatsoever between states and their ability to impose taxes upon its own citizens without violating constitutional rights.