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In the Savings and Loan Society v. Multnomah County case of 1897, the U.S Supreme Court ruled in favor of Multnomah County. The dispute arose when a savings and loan society based in California purchased bonds issued by Multnomah County, Oregon. When it came time for the county to pay back its debt, they refused on grounds that their own state laws prohibited them from paying interest to out-of-state entities. The Savings and Loan Society sued but lost at both district court level and upon appeal at the Supreme Court level. In its decision, the Supreme Court held that while states cannot pass legislation impairing contractual obligations under Article I Section 10 Clause 1 of US Constitution (the Contract Clause), this prohibition does not apply if such contracts are made with foreign corporations or non-residents where payment is sought outside state borders.
The dissenting opinion in the Savings and Loan Society v. Multnomah County case argued that the majority's decision was inconsistent with previous rulings of the court regarding tax laws. The dissent pointed out that it had been previously established by this court that states have a right to impose taxes on personal property, including shares in corporations, regardless of where they are located or used. Therefore, Oregon’s law taxing shares held by residents should be upheld as constitutional under these precedents. Furthermore, they disagreed with the majority's interpretation of "due process," arguing instead for a broader understanding which would allow states more flexibility in their taxation policies without violating citizens' rights under federal law.