In the case of New York v. Eno in 1894, the U.S Supreme Court was tasked with determining whether a state had jurisdiction to tax personal property located outside its borders. The defendant, Mr. Eno, was a resident of Connecticut but owned stocks and bonds in corporations based in New York. The State of New York sought to tax these assets as they were physically present within its territory despite their owner residing elsewhere. The court ruled that while states have broad powers to levy taxes on residents and businesses within their boundaries, this power does not extend beyond those limits unless explicitly granted by Congress or allowed under international law principles. Therefore, it held that New York could not impose taxes on Mr. Eno's out-of-state assets simply because they were tied to companies operating within its borders. This decision reinforced the principle that each state has sovereignty over taxation matters within its own territory but cannot unilaterally extend this authority into other jurisdictions without consent or legal basis.

In the dissenting opinion for New York v. Eno, it was argued that the state of New York did not have jurisdiction over a crime committed on a ship in international waters. The dissenting justices contended that while the ship was owned by an American company and had departed from a port in New York, this did not give the state authority to prosecute crimes committed outside its territorial boundaries. They maintained that only federal courts should have jurisdiction over such cases under U.S maritime law and international law principles. Furthermore, they expressed concern about potential conflicts with other nations if individual states were allowed to exercise extraterritorial criminal jurisdiction based solely on ownership or departure point of vessels.