Miller v. The State was a United States Supreme Court case that addressed the issue of whether a state could impose a tax on a foreign corporation. The case involved a dispute between the State of Georgia and the Miller Iron Company, a foreign corporation. The state had imposed a tax on the company, which the company argued was unconstitutional. The Supreme Court held that the state had the right to impose the tax, as the company was doing business within the state and was thus subject to the state's laws. The Court noted that the company was not being discriminated against, as the tax was applied equally to all foreign corporations doing business in the state. The Court also noted that the tax was not excessive, as it was based on the company's profits and was not an arbitrary or excessive amount. The Court's decision established that states have the right to impose taxes on foreign corporations doing business within their borders. This decision has been cited in numerous cases since, and has been used to support the idea that states have the right to impose taxes on foreign corporations.

Justice Field delivered the dissenting opinion in Miller v. The State, arguing that the Fourteenth Amendment did not apply to state laws regarding criminal procedure and punishment. He argued that the amendment was intended to protect citizens from discrimination on account of race or color, but it could not be used as a basis for overturning a conviction based on an alleged violation of due process rights. Field further argued that if Congress had wanted to extend such protection against state action, they would have done so explicitly in their legislation rather than relying upon implication from other language within the amendment itself. Furthermore, he noted that allowing individuals convicted under existing state law to challenge those convictions through federal courts would undermine states' sovereignty and create chaos by potentially invalidating thousands of prior convictions across multiple jurisdictions. Ultimately, Justice Field concluded his dissent by asserting that any changes necessary should come through legislative action at either the federal or state level instead of judicial interpretation via constitutional amendments like the Fourteenth Amendment which were never meant for this purpose in mind