Sargent v. Burgess is a Supreme Court case from 1891 that dealt with the issue of whether a state could require a non-resident to pay a tax on the income they earned from property located in the state. The plaintiff, Sargent, was a non-resident of the state of Massachusetts who owned property in the state. The state had imposed a tax on the income he earned from the property, and Sargent argued that the tax was unconstitutional. The Supreme Court ultimately ruled in favor of the state, holding that the tax was constitutional and that the state had the right to impose it on non-residents. The Court reasoned that the tax was a legitimate exercise of the state's power to regulate commerce and protect its citizens, and that it did not violate the Due Process Clause of the Fourteenth Amendment. The decision established that states have the power to tax non-residents on income earned from property located within the state.

In the dissenting opinion of Sargent v. Burgess, Justice Field argued that the majority’s decision was in direct violation of a prior Supreme Court ruling from 1871 (Hepburn & Dundas v. Ellsworth). In Hepburn & Dundas, it had been established that when an individual has obtained title to land through a patent issued by the United States government, they are entitled to all rights and privileges associated with such ownership; this includes any water rights which may be attached to said property. The majority in Sargent v. Burgess held that these water rights were not included as part of the original grant and thus could not be enforced against subsequent purchasers or occupants who had no knowledge of them at time of purchase/occupancy - essentially overturning Hepburn & Dundas without explicitly stating so. Justice Field believed this was wrong and should have been addressed more directly rather than simply disregarded for convenience sake; he further noted how allowing such disregard would lead to confusion among landowners regarding their respective legal entitlements moving forward into future cases involving similar issues.