In the Saltonstall v. Russell case of 1893, the U.S. Supreme Court ruled on a dispute involving land ownership and inheritance rights. The plaintiff, Saltonstall, claimed that he was entitled to certain lands in California as an heir of his deceased uncle who had purchased them from Mexican citizens before California became part of the United States. He argued that under Spanish and Mexican law at the time of purchase, these lands would have passed directly to him upon his uncle's death without any need for a will or other formal conveyance. The defendant, Russell (the executor of another relative's estate), countered that since California had become part of the U.S., American laws applied instead - specifically those requiring formal transfer through wills or deeds. The Supreme Court sided with Russell stating that once California became a state within America it was subject to its laws regarding property succession rather than those previously established by Spain or Mexico.

In the dissenting opinion for Saltonstall v. Russell, the justice argued that a state's power to tax should not be limited by federal law unless explicitly stated in the Constitution. He contended that Massachusetts had every right to levy taxes on national bank shares held by its residents, even if those banks were located out of state. The majority ruling, he believed, undermined states' rights and threatened their financial stability by limiting their ability to generate revenue through taxation. Furthermore, he disagreed with the interpretation of "located" used in this case - arguing it was intended as where a bank conducts business rather than where it is incorporated or has its principal office. This disagreement over interpretation led him to conclude that Massachusetts could indeed tax these shares without violating any constitutional provisions or federal laws.