Ohio v. Frank was a United States Supreme Court case that dealt with the issue of whether a state could tax the income of a non-resident. The case involved a dispute between the state of Ohio and a man named Frank, who was a resident of Pennsylvania. Frank had received income from Ohio sources, and the state of Ohio sought to tax him on that income. Frank argued that the state of Ohio did not have the authority to tax him, as he was a non-resident. The Supreme Court ultimately sided with Frank, ruling that the state of Ohio did not have the authority to tax the income of a non-resident. The Court reasoned that the power to tax is an attribute of sovereignty, and that the state of Ohio did not have the power to tax a non-resident. The Court also noted that the power to tax is a fundamental right of the states, and that the state of Ohio could not infringe upon that right by attempting to tax a non-resident. The Court's ruling in Ohio v. Frank established that states do not have the authority to tax the income of non-residents. This ruling has been cited in numerous subsequent cases, and has been used to protect the rights of non-residents from taxation by states.

Justice Field delivered the dissenting opinion in Ohio v. Frank, arguing that the majority had erred in its interpretation of a state statute and thus wrongly decided the case. He argued that under Ohio law, when an executor or administrator is appointed to administer an estate, they are not personally liable for any debts incurred by their predecessor unless there is evidence of fraud or mismanagement on their part. The majority had held otherwise, finding that such liability was imposed regardless of fault on behalf of the successor executor or administrator. Justice Field disagreed with this conclusion and argued instead that it would be unjust to impose personal liability without proof of wrongdoing as it could potentially bankrupt those who take up these roles out of good faith service to others. Furthermore, he noted how such a ruling would discourage people from taking up positions as administrators and executors due to fear over potential financial ruin if something went wrong during administration despite no fault on their part; this would ultimately harm society at large since these roles are essential for proper management and distribution of estates after death.