In the case of Ormsby et al., Executors, v. Chase (1933), the United States Supreme Court was tasked with deciding whether a New York state law that imposed an estate tax on property transferred at death violated the Due Process Clause of the Fourteenth Amendment. The property in question had been placed into trust by a New Yorker who later moved to Connecticut and died there. The executors of his estate argued that since he was not a resident of New York at his time of death, it would be unconstitutional for New York to impose its transfer tax on his out-of-state assets. The Supreme Court disagreed with this argument and upheld the constitutionality of New York's transfer tax law. It ruled that because all necessary steps for transferring ownership were taken while he still resided in NY, it did not matter where he lived when he died or where his beneficiaries lived after receiving their inheritances; what mattered was where those initial transfers took place - which is why they could be taxed under NY laws without violating due process rights.

In the dissenting opinion for Ormsby et al., Executors, v. Chase, it was argued that the majority's decision to uphold a lower court ruling in favor of Chase contradicted established legal principles regarding trusts and estates. The dissenting justices believed that the trust created by Mr. Ormsby should have been considered valid under New York law because he had clearly intended to create a trust and had taken steps to do so before his death. They also disagreed with the majority's interpretation of certain provisions in Mr. Ormsby’s will, arguing that these provisions did not invalidate his intention to establish a trust for his wife during her lifetime and then distribute any remaining assets among their children after her death.