In the case of Milwaukee v. Koeffle, the Supreme Court of the United States was asked to decide whether a city could impose a tax on the transfer of real estate. The city of Milwaukee had passed an ordinance that imposed a tax on the transfer of real estate within the city limits. The plaintiff, Koeffle, argued that the ordinance was unconstitutional because it violated the due process clause of the Fourteenth Amendment. The Supreme Court held that the ordinance was constitutional. The Court reasoned that the ordinance was a valid exercise of the city's police power, and that it did not violate the due process clause. The Court noted that the ordinance was a reasonable means of raising revenue for the city, and that it did not impose an undue burden on the transfer of real estate. The Court also held that the ordinance did not violate the equal protection clause of the Fourteenth Amendment. The Court reasoned that the ordinance was not discriminatory, and that it applied equally to all persons who transferred real estate within the city limits. In conclusion, the Supreme Court held that the ordinance was constitutional, and that it did not violate the due process or equal protection clauses of the Fourteenth Amendment.

In the case of Milwaukee v. Koeffle, the Supreme Court was tasked with deciding whether a city could impose an annual tax on real estate owned by non-residents. The majority opinion held that such taxation was permissible under the Constitution and did not violate any rights of citizens or states. However, Justice Field dissented from this decision, arguing that it violated both state sovereignty and individual liberty. He argued that since cities are creatures of their respective states, they cannot exercise powers beyond those granted to them by their parent state government; thus taxation without permission would be unconstitutional as it would amount to an infringement upon state authority over its own internal affairs. Furthermore, he argued that allowing cities to levy taxes on property belonging to non-residents deprived them of due process protections guaranteed in the Fourteenth Amendment which guarantees all persons equal protection under law regardless of residence status or citizenship status. Therefore Justice Field concluded that such taxation should not be allowed as it violates fundamental constitutional principles regarding federalism and civil liberties for individuals living outside a given jurisdiction's boundaries