Oregon v. Jennings was a United States Supreme Court case that addressed the issue of whether a state could impose a tax on a non-resident's income from a business located in the state. The case was brought by Oregon resident, William Jennings, who was a partner in a business located in Oregon. Jennings argued that the state's tax on his income from the business was unconstitutional because it violated the Due Process Clause of the Fourteenth Amendment. The Supreme Court disagreed and held that the tax was constitutional. The Court reasoned that the tax was a valid exercise of the state's power to tax and regulate businesses within its borders. Furthermore, the Court held that the tax did not violate the Due Process Clause because it was applied equally to all non-residents who conducted business in the state. The Court also noted that the tax was not so onerous as to be an unreasonable burden on interstate commerce. As a result, the Court held that the tax was constitutional and that Oregon could impose it on non-residents.

Justice Field delivered the dissenting opinion in Oregon v. Jennings, arguing that the state of Oregon had no right to bring a suit against an individual citizen for damages resulting from a breach of contract. He argued that since there was no law authorizing such suits, and since it would be contrary to public policy for states to sue individuals without legislative authority, the court should not recognize this action as valid. Furthermore, he noted that if such actions were allowed then any state could pass laws allowing them to sue citizens at will and thus deprive them of their constitutional rights with impunity. Justice Field concluded by stating his belief that only Congress has the power to authorize such suits between states and citizens; therefore, this case should have been dismissed on jurisdictional grounds rather than decided on its merits.